Bijou Bangles Silver Limited
GDPR/Privacy Statement - May 2018.
Bijou Bangles Silver Limited (BBS) 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 always had a robust and effective data protection programme in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this programme to meet the demands of the GDPR and the UK’s Data Protection Bill.
BBS is 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 of the new Regulation. Our preparation and objectives for GDPR have been summarised in this statement, to ensure ongoing compliance.
How We have Prepared for the GDPR
BBS already has a consistent level of data protection and security. Additional measures to comply with the new GDPR regulations include:
- Information Audit - carrying out an 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 relevant policies and procedures to meet the requirements and standards of the GDPR, including: -
- Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. We understand 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 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. Our procedures have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
- International Data Transfers & Third-Party Disclosures – we do not store any personal information outside the EU.
- Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge.
- 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.
- 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 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 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.
- 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 procedures for carrying out impact assessments.
- Processor Agreements – where we use any third-party to process personal information on our behalf (e.g. employee, payment or payroll information), we have compliant processes 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 the office of an individual’s right to access any personal information that BBS 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 the 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
BBS 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.
GDPR Roles and Employees
BBS has designated Christine Muchmore as our Appointed Person to implement our roadmap for complying with the new data protection Regulations.
BBS understands 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 Christine Muchmore, via Bijou Bangles Silver on: [email protected]