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.
Christy Plumbing & Heating Ltd is 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 programme 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.
Christy Plumbing & Heating Ltd is dedicated to safeguarding the personal information under our 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. Our 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.
How We are Preparing for the GDPR
Christy Plumbing & Heating Ltd already has a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR by 25th May 2018. Our preparation includes: –
Information Audit – carrying out a company-wide information 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.
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 – 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. 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 time-frames 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 time-frame 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 a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
Firewall – Christy Plumbing & Heating Ltd subscribes to Norton Security and keeps this updated.
Legal Basis for Processing – we are 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, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
Privacy Notice/Policy – we are revising 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 are revising 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. We have developed stringent processes for recording consent, making sure that we 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 – we do not carry out direct marketing.
Data Protection Impact Assessments (DPIA) – this is not applicable to our Company.
Processor Agreements – this is not applicable to our Company.
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 all 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. Where we 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, we provide easy to access information via our website, in the office, during enquiry of an individual’s right to access any personal information that Christy Plumbing & Heating Ltd processes about them and to request information about: –
- 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
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Customers are defined as being domestic or commercial customers whether as an individual or a company or organisation. We will hold the customer’s name, address , site address (if different) , telephone numbers and email. We will also hold details of past jobs, estimates, quotes , invoices and emails. At the point of enquiry or order we will outline that we will hold these details for the duration of them being a customer of Christy Plumbing & Heating Limited and until they opt-out. On our terms and conditions this information will be detailed as well as the procedure for customers to opt out and have their information erased. Financial information such as receipts or invoices will be kept by Christy Plumbing & Heating ltd for the period requested by HM Revenue & Customs. All customers will be informed that personal information relating to their job/enquiry will only be shared with employees of Christy Plumbing & heating Ltd and not shared with third parties. Christy Plumbing & Heating Ltd does not carry out direct marketing and only carries out a reminder service for appliance servicing.
GDPR Roles and Employees
Christy Plumbing & Heating Ltd has designated Sarah Christy as our Data Appointed Person . She is responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
Christy Plumbing & Heating Ltd understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR . We have implemented an employee training program specific to the which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.
If you have any questions about our preparation for the GDPR, please contact Sarah Christy.
The following information sheet is given to customers:
Protecting Your Privacy
If you’re still happy to receive information from us, then you don’t need to do anything more and we’ll continue to contact you. If you would prefer not to hear from us, then email, telephone or send us an instruction that you wish to opt out and for us to erase your personal data.
What Information Do We Collect?
We collect and process a range of information about you, including your name, address and contact details (including email address and telephone numbers), correspondence relating to any contract and services provided, including any purchases.
We may collect this information in a variety of ways, e.g. email or telephone or by post. Data is kept in the organisation’s management systems which include our office computer’s , mobile phones and hardcopy storage files.
Why Do We Process Your Data?
We need to process data to pursue your enquiry or booking for works. Data will only be used for the purpose it was obtained. Processing your data allows us to:
- Maintain accurate and up-to-date contact information.
- Record contractual information.
- Use information provided for the sole purpose of facilitating the provision of service.
- Maintain details of the products and services you use.
- Make and receive payments in accordance with contracts and agreements.
- Respond to and defend against warranty, legal or insurance claims.
Who Has Access To Your Data?
Data may be shared internally so that we can provide you with a complete service. Your data is only shared with third parties in order to register warranties or supply information to comply with buildings regulations. We will never sell your data to a third party for the purposes of marketing.
How Do We Protect Data?
We take the security of your data seriously. Internal policies and controls are in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the performance of their duties.
Where the organisation engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (‘EEA’). It may also be processed by staff operating outside the EEA who work for one of our suppliers and may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely.
How Long Do We Keep Data?
The organisation will hold your personal data for the duration of your contract with us and for a period as necessary after the contract ceases, to maintain customer service.
As a data subject, you can:
- Know what personal data is processed.
- Access your data by way of a subject access request.
- Correct inaccurate personal data.
- Erase personal data when there is no right to process it or it is no longer necessary for the purpose it was collected.
- Request the restriction of processing data if requesting deletion or correction.
- Object to data processing where we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop.
- Object if we process your personal data for the purposes of direct marketing unless your permission has been granted.
- Be notified of a data security breach concerning your personal data
- Complain to the Information Commissioner. You can do this be contacting the Information Commissioner’s Office directly. Full contact details including a helpline number can be found on the Information Commissioner’s Office website.
If you believe that we have not complied with your data protection rights, in the first instance please contact Sarah Christy (Data Protection ) on 01234325620 or firstname.lastname@example.org you can complain to the Information Commissioner.”