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Minor, Weir & Willis 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 General Data Protection Regulation (GDPR) which came into force on 25th May 2018.
Minor, Weir & Willis are 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.
You can see a copy of this Customer Data Privacy Notice at mww.co.uk/privacy
HOW WE ARE PREPARED FOR THE GDPR
We have been preparing for GDPR and have carried out the following actions:
We are 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 – we are implementing new 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.
The Board of Directors have reviewed its obligations under the GDPR regulations. Because the company’s principle activities do not involve “regular and systematic monitoring of data subjects on a large scale” or large-scale processing of “special categories of personal data” the Board concluded that the appointment of a Data Protection Officer is not required. However it has appointed a data compliance team that will ensure that our obligations under the GDPR are met. The head of the data team will be the DATA Protection Compliance Manager and they will be the first point of contact in dealing with privacy enquiries. The compliance Manager can be contacted by emailing email@example.com
TRAINING – We are training our data compliance committee and other key staff to give them the necessary knowledge in discharging our obligation under GDPR
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.
INTERNATIONAL DATA TRANSFERS & THIRD-PARTY DISCLOSURES –We carry out strict due diligence checks with all recipients of personal data to assess and verify that they 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) – 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 a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
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 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. 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 are revising the wording and processes for direct marketing, including developing 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, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We are implementing 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 (i.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 organizational measures in place and compliance with the GDPR.
DATA SUBJECT RIGHTS
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, you have a right to ask MWW if we hold their personal information. This can be done via our website by emailing firstname.lastname@example.org or in writing by contacting
The Data Compliance Manager
Minor Weir and Willis Limited
206 Deykin Avenue
You have a right to know:
- What personal data we hold
- 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 you, information about the source
- The right to have incomplete or inaccurate data about you corrected or completed and the process for requesting this
- The right to request erasure (right to be forgotten) 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