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.
Full Circle IT Solutions 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 in updating and expanding this program to meet the demands of the GDPR.
Full Circle IT Solutions Ltd 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.
Full Circle IT Solutions Ltd already have a consistent level of data protection and security across our organisation, however this has been reviewed to ensure it is fully compliant with the GDPR.
Our Data About You
“Personal data”, or “personal information”, means any information about an individual from which that person can be identified.
If you are an individual contact at an organisation which is a client or a potential client of ours, we may collect your personal data such as your name, telephone number and email address. We may collect your personal data from you directly (e.g. when you submit information on our website) or from third party sources. This data is referred to as “Client Data” in this Policy.
How We Use This Data
We will only use your personal data for the purposes detailed in this Policy and when the law allows us to. These are:
- When you give your consent
- When necessary for the performance of a contract we have entered into or are entering into with you
- Any legal or regulatory obligation
- For our legitimate interests or those of a third party, provided that your interests and fundamental rights and freedoms do not override those interests.
This might include introducing or supplying services to your organization or the fulfillment of a contractual role you have requested.
Full Circle IT Solutions Ltd 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, including: -
- Cloud data storage – Third party data centres are utilised for our cloud storage requirements and recommendations. These are chosen for their advanced levels of security, in terms of data availability (uptime) and security and encryption methods. These data centres are all UK based and we have full data protection statements from these suppliers in line with GDPR recommendations.
- Web hosting – A third party hosting solution is deployed for all our web hosting requirements. All data is held within UK data centres and have been chosen due to the levels of security, up time and encryption.
- Email services – We have two suppliers of email services: exchange email and Office365. Both are Microsoft services, with Office365 being supplied directly via Microsoft and exchange email via a third party solution.
- Internal Systems – our internal systems are secured via an SSL certificate, passwords are changed regularly, and all servers are maintained with the latest vendor patches and updates.
Where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have obtained Compliance Statements from them to ensure 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.
Our wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; have been revised and a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
In preparation for the onset of GDPR, we have carried out an information audit, looking at the personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed. We have reviewed our policies and procedures, including our Retention Policy, Breach Policy, Erasure Policy and Subject Access Request Procedure.
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 on request by email of an individual’s right to access any personal information that Full Circle IT Solutions Ltd 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
GDPR Roles and Employees
Full Circle IT Solutions have designated Adele Tildsley as our Data Protection Officer (DPO) and, along with co-director Mark Brocklebank is full committed to ensuring that the company complies with the new data protection Regulation. The directors 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. Full Circle IT Solutions Ltd 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.
If you have any questions about our preparation for the GDPR, please contact Adele Tildsley.