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The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.
The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
I am committed to ensuring the security and protection of the personal information that is processed, and to provide a compliant and consistent approach to data protection. I have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, I recognise new obligations in updating and expanding this program to meet the demands of the GDPR and the current U.S. Privacy Protection laws.
I am dedicated to safeguarding the personal information under my remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. My preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
I already have a consistent level of data protection and security across my organisation, however it is my aim to be fully compliant with the GDPR by August 2018. Preparation includes:
- Information Audit – carrying out a company-wide information audit to identify and assess what personal information I hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
- Policies & Procedures – revising data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
- Data Protection – my main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that I understand and adequately disseminate and evidence my personal obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
- Data Retention & Erasure – I have updated my retention policy and schedule to ensure that I meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. I have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and am aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
- Data Breaches – my breach procedures ensure that I have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. My procedures are robust and have been disseminated to any employees or contractors, making them aware of the reporting lines and steps to follow.
- International Data Transfers & Third-Party Disclosures – where I might store or transfer personal information outside the EU, I have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. My procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. I carry out strict due diligence checks with all recipients of personal data to assess and verify that we have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
- Subject Access Request (SAR) – I have revised my SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. These new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
- Legal Basis for Processing – I am reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, I also maintain records of our processing activities, ensuring that my obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
- Privacy Notice/Policy – I have revised my Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information I process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
- Obtaining Consent – I have revised my consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how it is used and giving clear, defined ways to consent to the processing of their information. I have developed stringent processes for recording consent, making sure that I can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
- Direct Marketing – I have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
- Data Protection Impact Assessments (DPIA) – where I process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; I have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. I have implemented documentation processes that record each assessment, allow me to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
- Processor Agreements – where I use any third-party to process personal information on our behalf (e. Payroll, Recruitment, Hosting etc), I have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as I), meet and understand their/my GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.
- Special Categories Data – where I obtain and process any special category information, I do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where I have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where I rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, I provide easy to access information via my website and by direct e-mail contact of an individual’s right to access any personal information that I process about them and to request information about: –
- What personal data I hold about them
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long I intend to store your personal data for
- If I did not collect the data directly from them, information about the source
- The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
- The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from me and to be informed about any automated decision-making that I use
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances