Bransom Retail Systems Ltd ('we' or 'us' or 'our') 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 and have updated and expanded this program to meet the demands of the GDPR.
We are dedicated to safeguarding the personal information under our remit and have developed a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulations. 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.
How We have Prepared for the GDPR
We already have a consistent level of data protection and security across our organisation, however we have ensured we are fully compliant with the GDPR for 25th May 2018. Our preparation included: -
- 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 – revised our data protection 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. 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 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. We have expanded this to the data we hold from client's software and will ensure that should we require a copy to be brought back for testing or investigation that we seek authorisation, it is stored securely, data is scrambled where possible and not in relation to the incident logged and it is destroyed once the requirement is fulfilled and completed.
- 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 – we do not store or transfer any data outside the UK and EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. 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 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 have reviewed all processing activities to identify the legal basis for processing and ensure 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.
- 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 way to see, access and withdraw consent at any time.
- Direct Marketing - we have revised the approach 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.
Information Security & Technical and Organisational Measures
Bransom Retail Systems Ltd 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 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: -
- Business Class encrypted wifi in our offices
- Business Class firewalls and VPNs
- SSL access to public facing websites
- AES256 bit encryption on external backups
- TLS protocols and Oauth authentication on our mPoS software
We have also recently upgraded all internal servers to the latest versions of operating system, which are regularly patched.
GDPR Roles and Employees
Bransom Retail Systems Ltd has designated Emma Garland as our Data Protection Lead to develop and implement our roadmap for complying with the new data protection Regulation. 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.
We understand 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 which has been provided to all current employees, and forms part of our induction and annual training program going forwards.
If you have any questions about our preparation for the GDPR, please contact firstname.lastname@example.org or on 01442 256445.