The EU General Data Protection Regulation (“GDPR”) came into force across the European Union on 25th May 2018 and brought 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 new regulation aims to give individuals stronger, more consistent rights to access and control their personal information.
Momentous Change Ltd is 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 a particular regard to ethical as well as compliant use of personal data, with a commitment to ensure that no individual suffers harm.
Momentous Change Ltd is committed to safeguarding the personal information under our control and in continually developing a data protection regime that is effective.
We already have a consistent level of data protection and security across our organisation. The following summarises key areas.
- · Policies & Procedures – our data protection practices and procedures meet the requirements and standards of the GDPR including: -
- o Data Protection –Accountability and governance are in place to ensure that we understand, adequately disseminate and evidence our obligations and responsibilities; with a focus on privacy by design and the rights of individuals.
- o Data Retention & Erasure – we meet the ‘data minimisation’ and ‘storage limitation’ principles. All personal information is stored, archived and destroyed compliantly and ethically.
- o Data Breaches – we are able to identify, assess, investigate and report any personal data breach at the earliest possible time.
- o Subject Access Request (SAR) – our SAR practices accommodate the 30-day timeframe for providing the requested information and for making this provision free of charge.
- · Privacy Notice/Policy – we are fully 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, to whom the information is disclosed and what safeguarding measures are in place to protect their information.
- · Obtaining Consent - we have updated 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 way to withdraw consent at any time.
- · Direct Marketing - we do not directly market our services via information held on individuals in our company.
- · Data Protection Impact Assessments (DPIA) – As a matter of company policy, we do not process personal information that is considered high risk in any way.
- · Special Categories Data - where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements. 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 office. This includes requesting 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 or to restrict processing in accordance with data protection laws, as well as to object to any direct communication from us.
- · The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Information Security & Technical and Organisational Measures
Momentous Change Ltd takes the privacy and security of individuals and their personal information very seriously and takes every reasonable measure and precaution to protect and secure the personal data that we process.
GDPR Roles and Employees
Momentous Change Ltd has designated Roger Mullin as our Data Protection Officer.
We understand that continuous employee awareness and understanding is vital to the continued compliance of the GDPR.
If you have any questions about our preparation for the GDPR, please contact Roger Mullin.