The General Data Protection Regulation (“GDPR”) came into force across the European Union on 25th May 2018.

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.

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 programme in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this programme to meet the demands of the GDPR.

Cabinets Direct 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 a new data protection role, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

Cabinets Direct already have a consistent level of data protection and security across our organisation.

This 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 - Implementing 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 revised to meet the standards and requirements of 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 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 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 possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow. 

• 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.

• 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. 

• Privacy Notice/Policy – we have revised our Privacy Notice 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 - we have introduced a 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 and recording that 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 purposes.

• Data Protection Impact Assessments (DPIA) – we do not process data which is high risk.

• 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.

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 in the office and during induction of an individual’s right to access any personal information that Cabinets Direct 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

• 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

Cabinets Direct 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. 

Cabinets Direct have designated Nick Dawks as our Appointed Person to develop and comply with the new Data Protection Regulations.

 

Cabinets Direct 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 to which will be provided to all employees prior to May 25th 2018, and forms part of our induction and annual training programme.

If you have any questions about our preparation for the GDPR, please contact Nick@cabinetsdirectuk.com / 01945 870151