GDPR Policy

The Organisation already has a consistent level of data protection and security, but we have introduced new measures to ensure compliancy.

• Completed Information Audit — we have identified that we DO NOTstore any sensitive personal data as it is defined by GDPR. We only store non-sensitive personal data that is required to conduct business. We have identified what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed, as well as GDPR compliance of downstream data processors.
• Revised Policies and Procedures — we have revised data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
  • Data Protection – our main policy and procedure document for data protection has been revised to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy and the rights of individuals.
  • Data Retention and Erasure – we have revised our retention policy and schedule to ensure that we meet the “data minimisation” and “storage limitation” principles and that personal information is stored, archived and destroyed in accordance with our obligations. We have procedures in place to meet the ‘Right to Access’(Article 15), ‘Right to Rectification’ (Article 16), ‘Right to Erasure’ (Article 17) obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
  • Data Breaches – our procedures ensure that we have safeguards in place to identify, assess, investigate and report any personal data breach as early as possible. Our procedures have been explained all employees.
  • International Data Transfers and Third-Party Disclosures – where the Organisation transfers or stores personal information outside the EU, we have robust procedures in place to secure the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as binding rules, or standard data protection clauses for those countries without.
  • Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge
• Legal Basis for Processing– our processing activities are in compliance with the Article 6.
• Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we 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 – we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information

• Direct Marketing – we 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 we process personal information that is considered high risk, we have developed stringent procedures for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us 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 we use any third-party to process personal information on our behalf (ie Payroll, Recruitment, Hosting, etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they meet and understand their/our GDPR obligations.