The arrival of new data privacy requirements were released in 2018. The modernization of data privacy is the General Data Protection Regulation (GDPR) and the new Data Protection Act (DPA) 2018. This will provide a single regulation across the European Union (EU) and place obligations on organizations that operate outside of the EU but provide goods or services to EU citizens.
66degrees is focused upon maintaining the highest standards for data privacy and EU regulatory requirements. We are dedicated to maintaining data integrity and privacy to meet or exceed EU regulations for data protection.
As part of our GDPR preparation process, we are reviewing and updating all our internal processes, procedures, data systems and documentation in order to help ensure that we are ready when GDPR comes into force in May 2018.
We will implement the relevant policies and practices to ensure we protect any data handled by 66degrees – for its employees, customers, suppliers, partners and stakeholders, specifically including the following:
- employees training and ongoing workshops on GDPR regulations and requirements.
- suppliers who process personal data on behalf of 66degrees and asked to provide details of their state of compliance with the GDPR.
- A GDPR statement is provided from any partners, clients, customers and suppliers,
How we have prepared for the GDPR
- Data Security Audit
- We continuously monitor and assess data for its location, availability, access controls and classification.
- Policies & Procedures
- We have modernized our data protection policies and procedures to meet the requirements and standards of the GDPR
- Data Protection
- Our primary policy and procedure document for data protection has been adjusted 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 data destruction 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.
- International Data Transfers & Third-Party Disclosures
- Where 66degrees 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 not deemed adequate. We carry out strict quality control reviews 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 timeframe for providing the requested information. 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. 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 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.
- Obtaining Consent
- We are revising our consent mechanisms for obtaining personal data to be more transparent, 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 Protection Impact Assessments (DPIA)
- where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures 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
- 66degrees does not enter into 3rd party processor agreements at this time.
- Special Categories Data
- To the extent we obtain and process any special category information, we do so in compliance with the Article 9 requirements and have high-level encryption 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.
Our GDPR actions to date
- we are reviewing and updating our range of policies, including our Data Protection Policy
- we are undertaking a systematic review of the personal data we store, manage, maintain, collect, process and control
- we have assessed our lawful bases for processing data to ensure all personal data is processed lawfully, fairly and transparently
- we have introduced legitimate interest assessments where we rely on legitimate interest as the lawful basis for processing any personal data
- we have conducted data mapping of all our processes involving personal data
- we are providing training to our employees and generally raising the awareness and importance of GDPR to our business and their individual responsibilities arising from this
- we are and will continue to look at ways of improving our systems and procedures to better comply with GDPR best practice
Should you require any further information about 66degrees and our GDPR plans and preparation, please contact us using the details below: