GDPR Compliance Statement
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.
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 at West
Coast Campervans 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 Data Protection Act 1988 in
conjunction with the Data Protection Amendment Act 2003.
West Coast Campervans 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
We are Preparing for the GDPR
Our preparation includes: –
- West Coast Campervans are committed to training Staff in compliant data collection, correlation and disposal
- West Coast Campervans 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 by 25th May 2018.
- 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
- Policies & Procedures –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 West
Coast Campervans 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 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.
- Privacy Notice/Policy – we have revisedour 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 – we have revisedour 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 revisedthe 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.
- 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 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.
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, in the office, during inductionof an individual’s right to access any personal information that West Coast Campervans 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
- 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
Security & Technical and Organisational Measures
West Coast Campervans 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: – Very restricted Access to database with Password
protection and SSL.
Roles and Employees
West Coast Campervans have designated Gavin
Gerrardas our Data Protection Officer to develop and
implement our road map for complying with the new data protection regulation.
She shall be responsible for
promoting awareness of the GDPR across the organisation, assessing our
GDPR compliance, identifying any gap
areas and implementing the new policies, procedures and measures.
West Coast Campervans 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 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:
Mr. Gavin Gerrard
West Coast Campervans
20 Main Street