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 are preparing for the GDPR
At ShieldSquare, we already have a consistent level of data protection and security across our organization. We are fully committed to be compliant with the GDPR by April 2018, well ahead of the deadline.
Our preparation includes:
Risk Assessment - 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 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. We will ensure that we adequately train 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.
DPA – 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. However, we recognize the requirement and importance of updating and expanding this program to meet the demands of the GDPR.
Getting ready for the GDPR
Information Security & Technical and Organizational Measures
ShieldSquare takes the privacy and security of individuals and their personal information very seriously and are taking 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, and have involved our employees in our preparation plans. We have implemented an employee awareness program specific to GDPR regulations, and will update our training protocol as and when necessary.
For more information about ShieldSquare’s GDPR compliance, please contact us at firstname.lastname@example.org