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PRIVACY POLICY

  

GDPR Compliance Statement

Our Commitment

Newplumb (we or us or our) are committed to ensuring the security and protection or 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 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 need the demands of the GDPR.

Newplumb are dedicated to safeguarding the personal information under our remit, and in developing a data protection regime that is in 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.

Newplumb 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 completing 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 - data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including

o Data Protection - our main policy and procedure 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 be 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 and exemptions, response timeframes and notification responsibilities.

o Data Breaches – our breach policy ensures that we have the 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.

o Third-Party Disclosures – we do not share your information with Third-Parties.

o Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, which steps to take for processing and access request, what exemptions apply and a suite of response templates to ensure that communication 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 for our processing activities ensuring our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are being met. 

· Privacy Notice/Policy – our revised Privacy Notices 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 safekeeping measures are in place to protect their information.

· 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.

· Direct Marketing – we do not participate in direct-marketing at this time, however, should there come a time when this becomes necessary, we will implement clear notices and methods of opting out of all subsequent marketing methods.

· 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 and assessment templates for carrying out impact assessments 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 activity and implement mitigating measures to reduce the risk posed to the data subject(s).

· 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.

  

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 and through our Data Protection Officer regarding an individual’s right to access any personal information that Newplumb 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

Newplumb 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: - 

• SSL; 

• Access Controls; 

• Password Policy; 

• Encryptions; 

• Restrictions; 

• Authentication 

GDPR Roles and Employees 

Newplumb have designated Lorraine Newport as our Data Protection Officer and have appointed a data privacy team to develop and implement our roadmap for complying with the ongoing compliance for GDPR. The team are responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.

Newplumb 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 specific to the 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 accounts@newplumb.co.uk