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 standardize data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
Smartcollection.co.uk is implemented by Karuny.com and we 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 recognize our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill.
Karuny.com 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 summarized 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 ARE COMPLYING WITH 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 – revising and implementing new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws.
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 minimization’ 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.
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 and partners involved in the development, maintenance, and support of smartcollection.co.uk, making them aware of the reporting lines and steps to follow.
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.
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 and are constantly revising 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 have and are constantly revising 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 have and are constantly revising 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.
Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Support, Product Development, 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 smartcollection.co.uk (this document) of an individual’s right to access any personal information that [Insert Organisation Name] 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
Karuny.com 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 unauthorized access, alteration, disclosure, or destruction and have several layers of security measures, including: –
- Websites using SSL Certificate to encrypt collection of any personal data.
- Only the development team consist of 3 people have access to all data collected on this website and they are instructed to treat this data as private and not under any circumstances hand this data over to any 3rd party without obtaining written consent from the user.
- After termination of a contract with Karuny.com, we will delete all your personal data within 4 weeks from our system, unless user has requested us to store all or some data in a longer period requested by the user.
- All our datacentres storing personal data are stored in Germany with our hosting partnerhttps://www.hetzner.com who are GDPR compliant. Their data privacy statement can be found here: https://www.hetzner.com/rechtliches/datenschutz/
If you have any questions about our preparation for the GDPR, please contact Morten Abrahamsen
Phone: +44 114 360 0744