The EU General Data Protection Regulation (‘GDPR’) came into force across the European Union on 25th May 2018 and brought with it the most significant changes to data protection law in two decades.
Based on privacy by design, and taking a risk-based approach, GDPR is intended to meet the requirements of the digital age.
As such, the new GDPR legislation will standardise data protection laws and processing across the EU and afford individuals stronger, and more consistent, rights to access and control their personal information.
At Apollo, we are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We 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, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill.
As such, we have safeguarded personal information under our remit and developed a data protection regime that is effective, fit for purpose, and demonstrates an understanding of, and appreciation for, the new regulation.
Our preparation and objectives for GDPR compliance are summarised in the below statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How We are Preparing for the GDPR
At Apollo, we already had a consistent level of data protection and security across our organisation.
However, to better align ourselves with GDPR, we have strengthened this, by:
- Undertaking an Information Audit – this entailed carrying out a broad audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
- Updating our Policies & Procedures – to ensure our data protection policies and procedures meet the requirements and standards of the GDPR, and other relevant data protection laws, including: –
- Data Protection – our 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 we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
- Data Retention & Erasure – we have updated 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 compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ 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 breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
- 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. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply, and how we can ensure that communications with data subjects are compliant, consistent and adequate.
- 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.
- Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; 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 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 (e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our 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 we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition.
Data Subject Rights
In addition to the policies and procedures mentioned above, that ensure individuals can enforce their data protection rights, we have established procedures which comply with an individual’s right to access any personal information that we, Apollo, hold about them.
This entitles individuals to learn, quickly:
- What personal data we 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 we intend to store your personal data for
- If we 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 us and to be informed about any automated decision-making that we use
Information Security & Technical and Organisational Measures
At Apollo, we take the privacy and security of individuals and their personal information very seriously, and we take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction. These include:
A revised password policy for all staff; encryptions and password protections on all client files; and improved, internal IT security protections.
GDPR Roles and Employees
Internally, we have appointed two of our team to maintain and comply with the new data protection Regulation.
They have responsibility for promoting awareness of the GDPR, identifying the need for further changes across the organisation, and implementing new policies, procedures and measures.
We also understand that improving employee awareness and understanding is vital to our continued compliance with GDPR, and, accordingly, we have apprised – and will continue to apprise – all of our staff about our policy and procedural updates.
We have provided a detailed overview of our compliance procedures to all employees, and, thenceforward, this will form part of our induction programme for new starters.
New employee contracts and our internal employee handbook have also been revised.
If you have any questions about our revised policy, and the steps we have taken to align ourselves with the new GDPR legislation, please contact our Data Protection Officer, David Yorath, via e-mail, at firstname.lastname@example.org
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