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- Raymond Hecek Accountants
- GDPR Compliance 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.
Our Commitment
Raymond Hecek Accountants 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 recognise
our obligations in updating and expanding this program to meet
the demands of the GDPR and the UK’s Data Protection Bill.
Raymond Hecek Accountants 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 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.
Raymond Hecek Accountants already has a consistent level of data
protection and security across our organisation and are fully
compliant with GDPR
• Information Audit – 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.
• Policies & Procedures – Our 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 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.
o Data Retention & Erasure – our retention policy and schedule
to ensures that we meet the ‘data minimisation’ and ‘storage
limitation’ principles and that personal information is stored,
archived and destroyed compliantly and ethically. We have
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.
o 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.
o International Data Transfers & Third-Party Disclosures – where
Raymond Hecek Accountants 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.
o 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 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 – Our Privacy Notice(s) 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 - 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.
• 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).
• 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.
• Special Categories Data - where we obtain and process any
special category information, we do so in complete compliance
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 easy to access information for an individual’s right to
access any personal information that Raymond Hecek Accountants
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
Raymond Hecek Accountants 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.
GDPR Roles and Employees
Raymond Hecek Accountants have a data privacy policy to
develop and implement our roadmap for complying with the new
data protection Regulation
Raymond Hecek Accountants 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 us.
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