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.

 

What are Vizual Management Solutions Limited doing to be GDPR ready?

Vizual Management Solutions Limited (‘we’ or ‘us’ or ‘our’) 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 to meet the demands of the GDPR and the UK’s Data Protection Bill.

As part of our continuous focus on information security and data privacy we have been getting ready for GDPR through a managed programme of activities in the following areas:

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.

Information Security

Reviewing and improving our information security framework, ensuring that our incident response process remains effective and that confidentiality, integrity and availability of personal information is assured through appropriate technical and organisational measures.

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.

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.

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.

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.

Data Protection Impact Assessments (DPIA)

Where we process personal information that includes special category data (biometric data) we have developed procedures 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 such as biometrics (where used for ID purposes), we do so in compliance with the Article 9 requirements and have protection on all such data.

 

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 request in the office, during induction etc of an individual’s right to access any personal information that Vizual Management Solutions Limited processes about them and to request information about: –

 

What personal data we hold about themThe purposes of the processingThe categories of personal data concerned
The recipients to whom the personal data has/will be disclosedHow long we intend to store the personal data forIf 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 thisThe 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 useThe right to lodge a complaint or seek judicial remedy and who to contact in such instances

 

Information Security & Technical and Organisational Measures

We take 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: –

  • The deployment of robust commercial grade firewalls.
  • The deployment of commercial grade Antivirus/malware solutions with central administration and monitoring.
  • The prompt deployment of patches and upgrades to our operating systems and hardware
  • Using the vendor recommended security features and deployment techniques when deploying systems (especially if they are externally accessible)
  • Offsite primary hosted email server & mail scanning
  • Staff awareness of the likely threats that depend on human interaction
  • Off site, off line backups
  • Offsite web servers for the most likely points of attack
  • Virtualisation of key servers
  • PC’s are password protected to an appropriate level of password policy with a forced change of password on a timed basis.

 

GDPR Roles and Employees

We have a designated Data Protection Officer (DPO) 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. We understand that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and are involving our employees in our preparation plans.

Our data protection arrangements and privacy mindset ensure that our operations are subject to continuous review to maintain alignment with GDPR. As we complete our preparations and as we introduce new products and services, the information provided here will therefore be updated periodically.

If you have any questions about our preparation for the GDPR, please email gdpr@vizualms.co.uk

 

Last updated: 25-05-18

 

 

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