GDPR Compliance Statement
Introduction 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 standardize data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
Our Commitment Barrs Security locksmiths uk limited 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 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.
Barrs Security locksmiths uk limited 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.
How we are preparing for the GDPR Barrs Security locksmiths uk limited already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR.
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/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. 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.
International Data Transfers & Third-Party Disclosures – where Barrs Security locksmiths uk limited stores or transfers personal information outside the EU, we have robust 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; standard data protection clauses 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.
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.
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 – 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 have revised the wording and processes for direct marketing, including 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 have implemented 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 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 encryption 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 of an individual’s right to access any personal information that Barrs Security locksmiths uk limited. 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
Information Security & Technical and Organisational Measures Barrs Security locksmiths uk limited. takes the privacy and security of individuals and their personal information very seriously and takes 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 and have several layers of security measures, including: - Access controls, password policy, encryption, practices, restriction, IT, authentication etc.
GDPR Roles and Employees Barrs Security locksmiths uk limited. has designated Victor Grist as our Appointed Person and has appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team is responsible for promoting awareness of the GDPR across the organization, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
Barrs Security locksmiths uk limited. understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific 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 Victor Grist.
1.1 In this policy, “we”, “us”, “our” refer to Barrs Security Locksmiths UK Limited and “you” and “your” refer to our customers.
1.2 We are committed to protect the private data we receive and store from you and respect your rights under the General Data Protection Regulation.
1.3 This policy applies when we receive your data and we are acting as “data controller” and when we process it and we are acting as “data processor”.
1.4 For more information about us and how you can contact us, please see Section 10.
1.5 Credit: This document was created using a template from the Master Locksmiths Association that is made available to members only.
Origin of our data
2.1 We only collect information directly from our customers (you) for schedule and financial purposes, before a job (when the customer gets in contact with us), or at the end of a job, when details such as name and address are requested to create a VAT invoice. Processing your data
In this section we explain how we use your personal data.
3.2 Your data will be use as correspondence data Barrs Security Locksmiths UK Limited may contact you by e-mailing or calling to give you updates on the service required or to send you a written quote). The legal basis of processing the correspondence data is the legitimate interest to perform a service, requested by you from us. Your data will be used as transaction data and it may be used for financial records such as VAT invoices and it will be kept for 6 years. The legal basis of this processing are the “legal obligations” to which Barrs Security Locksmiths UK Limited is subject.
Sharing your details
4.1 Barrs Security Locksmiths UK Limited does not share your private data with any other third party.
5. Storing your data
5.1 This section explains how we store your private data and for how long.
5.2 Your private data may be printed and secured in our filing cabinets. The [cabinets/safe] are placed at our offices that is secured by high level security and an alarm system. We store our correspondence/schedule data for one year for the legitimate purpose of keeping a record of the job our company attends.
5.3 Your private data may be stored electronically on our servers that are based in the UK. Our computers are protected by password and anti-virus program, and they can only be accessed by our staff members.
6. Deleting your data
6.1 This section explains how we delete/destroy your data once is no longer needed. For more details about the length of time we store your data please see Section 3 (3.3) and 5 (5.2).
6.2 Once your private data is no longer relevant/needed Barrs Security Locksmiths UK Limited will permanently delete the electronic files.
6.3 Once your private data is no longer relevant/needed Barrs Security Locksmiths UK Limited will be shredded in a mannor that complies to the GDPR, to destroy the documents.
7. Data breaches
7.1 Barrs Security Locksmiths UK Limited has standard procedures to protect your details against data breaches such as passwords for electronic files, that are periodically changed (when a staff member leaves the company), alarms and secure filing cabinets for physical documents. For more details on how we securely store your documents please see section 5.
7.2 We back-up your data by creating an electronic copy of each document that is securely stored on our server based in the UK, that is protected by password and anti-virus program.
7.3 Barrs Security Locksmiths UK Limited understands the legal requirement to report a data breach to ICO (Information Commissioner's Office) in maximum 72h hours from the event. We also commit to inform every person that has been affected by the data breach.
8.1 We may update this policy in order to improve our data management.
8.2 We will notify you of any significant changes to this policy. 9. Your rights (GDPR rights of the natural person)
9.1 This section explains the rights, you have, as a data subject, in relation to your personal information.
9.2 To be informed about how, why and on what basis that information is processed.
9.3 To obtain confirmation that your information is being processed and to obtain access to it and certain other information, by making a subject access request— your request will be answered in maximum 7 days.
9.4 To have data corrected if it is inaccurate or incomplete.
9.5 To have data erased if it is no longer necessary for the purpose for which it was originally collected/processed, or if there are no overriding legitimate grounds for the processing (the right to be forgotten).
9.6 To restrict the processing of personal information where the accuracy of the information is contested, or the processing is unlawful (but you do not want the data to be erased), or where the employer no longer needs the personal information, but you require the data to establish, exercise or defend a legal claim.
9.7 To restrict the processing of personal information temporarily where you do not think it is accurate (and the employer is verifying whether it is accurate), or where you have objected to the processing (and the employer is considering whether the organisation’s legitimate grounds override your interests).
9.8 If you wish to exercise any of the rights in paragraphs, please contact the data protection officer on firstname.lastname@example.org.
10. Barrs Security Locksmiths UK Limited details
10.1 We are registered in the UK under registration number 6265761 and our registered office is at 329 Fulham Palace Road London SW6 6TE
10.2 You can contact us: a) by post to the address of our registered office b) by e-mail to email@example.com c) by telephone 02077367668