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. GDPR is also applicable to companies outside the EU that process EU citizens’ data. The GDPR has been designed to meet the requirements of today’s digitally interconnected world, and is based on the fundamentals of privacy by design and privacy by default. The GDPR brings with it broad use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new regulation aims to standardize data protection laws and processing across the EU, affording individuals stronger, more consistent rights to access and control their personal information.
How we comply with the GDPR
At ShieldSquare, we have always had a consistent level of data protection and security across our organization. We are fully compliant with the GDPR in every way applicable to our business:
Risk Assessment - We have performed 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 to whom it is disclosed.
Policies & Procedures - We have implemented 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. We have adequately trained our employees about GDPR directives to protect individual privacy rights under this law.
Data Retention & Erasure – We have updated our retention policy and schedule to ensure that we meet the ‘data minimization’ 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. We 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 possibility. Our procedures are robust and have been disseminated to all employees, who are aware of the reporting lines and steps to follow.
International Data Transfers & Third-Party Disclosures – Where ShieldSquare stores or transfers personal information outside the EU, we have stringent procedures and safeguarding measures in place to secure, encrypt, and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules, or approved codes of conduct for those countries without. 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.
Data Processing Addendum – Where we use any third-party to process personal information on our behalf, we have drafted compliant Processor Agreements and due diligence procedures to ensure that they (as well as we) meet and understand their/ our GDPR obligations. These measures include initial and ongoing reviews of the service(s) 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, we provide information via email to individuals to comply with their right to access any personal information that ShieldSquare 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
- 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 is to be contacted in such instances
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 data protection principles. We have updated and expanded this program to meet the demands of the GDPR.
ShieldSquare is dedicated to safeguarding the personal information under our remit. We have developed a data protection regime that is effective, fit for purpose, and demonstrates an understanding of, and appreciation for the new regulation. This GDPR compliance statement describes our new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
Information Security, Technical, and Organizational Measures for GDPR Compliance
ShieldSquare takes the privacy and security of individuals and their personal information very seriously. We take every reasonable measure and precaution to protect and secure the personal data that we process. We have dedicated information security policies and procedures in place to protect personal information from unauthorized access, alteration, disclosure or destruction, and have several layers of security measures, including secure APIs, access controls, password policies, data encryption, secure IT practices, and restrictions on access of confidential data by unauthorized personnel.
ShieldSquare understands that continuous employee awareness and understanding is vital to our continued compliance of the GDPR regulations. We have already implemented an employee awareness program specific to GDPR regulations, and have updated our training protocol to ensure compliance with these regulations.
For more information about ShieldSquare’s GDPR compliance, please contact us at email@example.com