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. Founded on the fundamentals of privacy by design and a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.
The 21st Century brings with it broad 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.
Andrew Underwood Commercial Sweeping Ltd and Andrew Underwood Industrial Services Ltd (‘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. 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 the requirement and importance of updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill.
Andrew Underwood Commercial Sweeping Ltd and Andrew Underwood Industrial Services Ltd are dedicated to safeguarding the personal information under our remit and to developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation plans for the GDPR have been summarised in this statement and includes 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
Andrew Underwood Commercial Sweeping Ltd and Andrew Underwood Industrial Services Ltd preparations have included: -
• Information Audit - undertaking a company-wide information audit that has identified and assessed the 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 new data protection policies and procedures to meet the requirements the GDPR and any relevant data protection laws, including: -
o Data Protection – our main policy and procedure document for data protection has been reviewed and amended 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.
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, should any personal data breach occur, at the earliest possibility. Our procedures are robust and have been disseminated to all employees, who are aware of the reporting lines and steps to follow. o International Data Transfers & Third-Party Disclosures – We will not disclose your data to third parties nor transfer data outside the UK
o Subject Access Request (SAR) – we have revised our procedures to accommodate the revised 1-month 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.
o 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 are also maintaining records of our processing activities, ensuring that our obligations under Article 30 of the GDPR are met.
o Obtaining Consent - we have revised 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.
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 in the office of an individual’s right to access any personal information that Andrew Underwood Commercial Sweeping Ltd and Andrew Underwood Industrial Services Ltd 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
Information Security & Technical and Organisational Measures
Andrew Underwood Commercial Sweeping Ltd and Andrew Underwood Industrial Services Ltd takes the privacy and security of individuals and their personal information very seriously and are taking every reasonable measure and precaution to protect and secure the personal data that we process. We have dedicated 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, that align directly to the 10steps of Cyber Security issued by the CESG in conjunction with the Cabinet Office, Centre for the Protection of National Infrastructure and Department for Business Innovation & Skills
GDPR Roles and Employees
Andrew Underwood Commercial Sweeping Ltd and Andrew Underwood Industrial Services Ltd have designated Data Protection Lead and have implemented an employee training programme.
If you have any questions about our preparation for the GDPR, please contact our Data Protection Lead, Andrew Underwood (email@example.com)
Client Privacy Notice
This privacy notice explains how Andrew Underwood Commercial Sweeping Ltd and Andrew Underwood Industrial Services Ltd will use any personal information we collect about you.
What information do we collect about you?
We collect information about you when you engage with us for our sweeping services. This information will relate to the service we provide which will include address details, information on fire place and details of flues.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we would be unable to fulfil our legal and regulatory obligations.
How will we use the information about you?
We collect information about you in order to provide you with the professional service you have engaged us for.
Who might we share your information with?
If you agree, we may email you about other products or services that we think may be of interest to you.
We will not share your information for marketing purposes with any other company.
How long do we keep hold of your information?
In principle, your personal data should not be held for longer than is required under the terms of our contract for services with you. This will be reviewed each year when we contact you to complete your annual service.
You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information please email or write to us using the contact details noted below.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
We would like to send you information about our products and services which may be of interest to you. If you have agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner's Office