HOW WE ARE PREPARING FOR THE GDPR

J & J Systems UK Limited already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR.

 Our preparation includes: –

• 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 – our main data protection policy has been revised and we have implemented new procedures to meet the requirements and standards of the GDPR, including: –
  • Protection – Accountability and governance measures are in place to ensure that we understand; as well as adequately share 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. That personal information is stored, archived and destroyed compliantly and ethically.  We have developed 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 time frames and notification responsibilities.

• Data Breaches – our breach procedures ensures 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 explained to all employees, making them aware of the reporting lines and steps to follow.
• International Data Transfers & Third-Party Disclosures – where J & J Systems 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. Ensuring enforceable data subject rights and have effective legal remedies for data subjects where applicable.
• Data Subject Access Request (DSAR) – we are revising our DSAR 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 – we are revising 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 are revising 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 do not carry out direct marketing but will review the wording and processes for direct marketing before we do undertake any such activity, 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) – we do not process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; however, should this be something we were to undertake in the future, we understand that we would require stringent procedures and assessment templates to be developed for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We would implement 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 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.
  • Special Categories Data – we do not processany special category information, however should we ever do so, we understand our obligation to 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 via staff inductions and of course visits to our office of an individual’s right to access any personal information that J & J Systems UK Limited processes about them and to request information about: –

• What personal data we hold about them
• Purposes of the processing
• 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

J & J Systems UK Limited 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 & training policies and procedures in place to protect personal information from unauthorised access; alteration, disclosure or destruction and have several layers of security measures, including: –

SSL, access controls, password policy, encryption, pseudonymisation, account and data access restriction & authentication policies and procedures, Cyber Essentials, ISO27001

 GDPR ROLES AND EMPLOYEES

J & J Systems UK Limited have designated Jacqueline Offen as responsible for GDPR developing and implementing our roadmap for complying with the new data protection Regulation. Jacqui is a qualified GDPR Practitioner  &  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.

 J & J Systems UK Limited 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, in the run up to compliance and forms part of our induction and annual training program.

GDPR Statement 2018-R1