GDPR Compliance Statement
West End Salon
Introduction
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.
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.
Our Commitment
We at West End Salon 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 theData Protection Act 1988 in conjunction with the Data Protection Amendment Act 2003.
West End Salon
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.
How We Prepare for GDPR
Our preparation includes: -
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West End Salon
are committed to training Staff in compliant data collection,
correlation and disposal
-
West End Salon
already have a consistent level of data protection and security across
our organisation, and are be fully compliant with the GDPR
-
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
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implementing new data protection policies and procedures to meet the
requirements and standards of the GDPR and any relevant data protection
laws, including: -
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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.
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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 End Salon 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.
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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.
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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.
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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.
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Direct Marketing
- we have revised 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.
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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.
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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.
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 our website, in the office, during induction of an individual’s right to
access any personal information that West End Salon
processes about them and to request information about: -
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What personal data we hold about them
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The purposes of the processing
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The categories of personal data concerned
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The recipients to whom the personal data has/will be disclosed
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How long we intend to store your personal data for
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If we did not collect the data directly from them, information about
the source
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The right to have incomplete or inaccurate data about them corrected or
completed and the process for requesting this
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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
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The right to lodge a complaint or seek judicial remedy and who to
contact in such instances
Information Security & Technical and
Organisational
Measures
West End Salon
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.
GDPR Roles and Employees
West End Salon
have designated Evita McCloskey as our Data Protection Officer to develop and implement our road
map for complying with the new data protection regulation. They 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 End Salon
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 has 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:
Evita McCloskey
West End Salon
84 West Street
Drogheda
Co. Louth