www.pickyrooms.com - EU/ UK GDPR Awareness & Compliance Policy Statement.

  1. Introduction.

This information and statement sets out our Compliance Policy.

 

  1. The EU General Data Protection Regulation (“GDPR”) came 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. These regulations will last within the United Kingdom, following the UK’s departure from the EU in 2019. The current transition period shall exist and continue until 31st December 2020.

 

  1. 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.

 

  1. Our Commitment:

    1. 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 believe 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 Act.

    2. Picky Rooms 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.

5.0. How We comply with the GDP:

            5.1 We already have a consistent level of data protection and security across our organisation,   however it is our aim to be continually be compliant with the GDPR. Our preparation includes:

            (a) 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.

            (b) Policies & Procedures - revising/implementing new data protection policies and        procedures to match the requirements and standards of the GDPR and any relevant data      protection laws, including:

            (c) 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.

            (d) 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.

            (e) 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.

            (f) International Data Transfers & Third-Party Disclosures – where Picky Rooms 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.

            (g) Subject Access Requests (SAR) – You have a right to know what information we hold on         you. 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.

            (h) Legal Basis for Processing - we have reviewed 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.

            (i) 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.

            (j) Obtaining Consent - we are revising 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.

            (k) Direct Marketing - we are revising 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.

            (l) 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).

            (m) 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.

            (n) 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         encryptions 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.

6.0. Data Subject Rights:

            6.1. 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 Picky Rooms 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.

 

7.0. Information Security & Technical and Organisational Measures:

            7.1. Picky Rooms takes the privacy and security of individuals and their personal            information very seriously and take 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;         SSL, access controls, password policy, encryptions, pseudonymisation, practices, restriction,       IT, authentication etc.

8.0. GDPR Roles and Employees:

            8.1. We have designated KHALIL SMITH as our Controller of Data and have appointed a data       privacy team to develop and implement our roadmap for complying with the new data           protection Regulation. The team 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.

            8.2. Picky Rooms 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 awareness program    specific to the above, which will be rolled out to all employees as quickly as possible. This   forms an ongoing part of our induction and annual training program.

9.0 Further Information:

            9.1  If you have any questions about our preparation for the GDPR, please contact our   Controller of Data on info@pickyrooms.com

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Tel: 0203 086 8897

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