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GDPR Statement
Introduction
The EU
General Data Protection Regulation ("GDPR") comes 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 standardise data protection laws and processing across
the EU; affording individuals stronger, more consistent rights to access and control their personal information.
Our Commitment
Backbone (UK) Limited 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 are in the process of becoming ISO 27001 and
NCSC Cyber Essentials Plus certified and 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 recognise our obligations in updating
and expanding this program to meet the demands of the GDPR and the UK's Data Protection Bill.
Backbone (UK) Limited 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 alignment have been summarised in this statement and include the development and
implementation of updated data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing
alignment.
Preparing for the GDPR
Backbone (UK) Limited maintain a consistent level of data protection and security across our organisation and we have
made preparations and adjustments so that we are aligned with the GDPR.
Our preparation and adjustments include -
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Risk Assessment
- we have carried 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.
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Policies & Procedures
- we have revised our data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant
data protection laws, including: -
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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.
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Data Retention & Erasure
- we have updated our retention policy 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 are robust and have been disseminated to all
employees, making them aware of the reporting lines and steps to follow.
-
International Data Transfers & Third-Party Disclosures
- where Backbone (UK) Limited 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 without. We carry out strict due diligence
checks 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
and for making this provision free of charge. Our updated 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 continually review 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 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.
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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.
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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.
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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 processing activity and implement mitigating measures
to reduce the risk posed to the data subject(s).
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Processor Agreements
- where we use any third-party to process personal information on our behalf (
e.g. 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 alignment with the GDPR.
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Special Categories Data
- where we obtain and process any special category information, we do so in complete accordance with the Article
9 requirements and have high-level encryptions 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.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights,
we provide information via email to individuals to comply with their right to access any personal information that Backbone
(UK) Limited 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 their 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
Backbone (UK) Limited 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. We are in the process
of becoming ISO 27001 and NCSC Cyber Essentials Plus Certified and have dedicated 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 secure APIs, access controls, password policies, data encryption, secure IT practices,
and restrictions on access of confidential data by unauthorized personnel.
Backbone (UK) Limited have appointed a data privacy team to ensure we align with the new data protection Regulation. The team are responsible for promoting awareness of the GDPR across our organisation on a continual basis.
If you have any questions regarding GDPR or Privacy, please email us at privacy@backbone.uk.com clearly stating PRIVACY REQUEST in the email subject field.