GDPR Compliance Statement
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.
Here at Elaine’s Travel Co. 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 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.
Elaine’s Travel Co. is committed 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
Elaine’s Travel Co. already have a consistent level of data protection and security across our organisation, however it is our aim to adhere with the GDPR requirements.
Our preparation includes: –
• Policies & Procedures – revising data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: –
o Data Protection – our main policy and procedure document for data protection is in line with 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.
o 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.
o 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.
o 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.
• 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 – GDPR regulations require explicit consent for all personal information that is to be shared with us is obtained from the data subject and all other members of the travelling party prior to submission. Further details can be found at https://ico.org.uk.
• Direct Marketing – any personal information shared with us must not be used for any other activity that requires explicit consent unless obtained in line with GDPR guidance.
• Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk 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, Global Distribution Systems etc), 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.
Data Subject Rights
Information Security & Technical and Organisational Measures
Elaine’s Travel Co. 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.
GDPR Roles and Employees
Elaine’s Travel Co. has nominated data privacy persons (Sarah Childs and Elaine Ferry) to develop and implement our roadmap for complying with the new data protection Regulation. Sarah and Elaine are 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.
Elaine’s Travel Co. understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and has involved our employees in our preparation plans. We have implemented an employee awareness to develop and ensure future GDPR compliance.
If you have any questions about our preparation for the GDPR, please email: firstname.lastname@example.org or email@example.com
Policy Reviewed May 2018