GDPR Statement of Compliance
The EU General Data Protection Regulation (“GDPR”) takes effect from 25th May 2018 across the European Union, replacing the Data Protection Act (DPA) 1998. The European Commission (EC) has passed GDPR as a regulation to strengthen and unify data protection laws for EU and UK citizens.
The GDPR has been designed to meet the requirements of the digital age, and addresses the electronic transfer of personal data, and new regulations aim to standardise data protection laws and processing across the European Union, affording individuals stronger, more consistent rights to access and control their personal information.
Moreover, the British Government has confirmed that the United Kingdom’s decision to leave the European Union will not affect the commencement of the GDPR.
Our Commitment to GDPR
Cadman Fine Wines Ltd (‘we’ or ‘us’ or ‘our’ or ‘Cadman Fine Wines’) are committed to ensuring the security 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 programme in place which complies with existing law and abides by the data protection principles. However, we recognise the requirement and importance of updating and expanding this programme to meet the demands of the GDPR and the Data Protection Act.
Cadman Fine Wines are dedicated to safeguarding the personal information under our remit, and to developing a data protection regime that is effective, fit for purpose, and demonstrates an understanding of, and appreciation for the new regulation. Although many elements required for GDPR are already in place, our preparation plans for the GDPR have been summarised for this statement and includes the development and implementation of new data protection roles, policies, procedures, controls, and measures to ensure maximum and ongoing compliance.
How we are preparing for the GDPR
Cadman Fine Wines have already committed to a consistent level of data protection and security across our organisation, however, it is our aim to be fully compliant with the GDPR by the deadline of 25th May 2018.
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 – Revising existing policies (and implementing where necessary) new procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, 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 responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
- Data Retention & Deletion – 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 both compliantly and ethically. We have dedicated deletion and erasure procedures in place to meet the new ‘Right to Erasure’ obligation, and are aware of when this and other data subjects’ 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 possibility. Our procedures are robust, and have been disseminated to all employees, who are aware of the reporting lines and steps to follow.
- Subject Access Request (SAR) – We have revised our SAR procedures to accommodate the revised 1-month timeframe for providing the requested information and for making this provision free of charge.
- Obtaining Consent – We are revising our consent mechanisms for obtaining personal data, ensuring that individuals understand what data they are providing, why and how we use it, and giving clear and 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 opt-out and withdraw consent at any time.
- 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.
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 our website [https://www.cadmanfinewines.co.uk/terms-and-conditions/] as well as at our registered business address, of an individual’s right to access any personal information that Cadman Fine Wines 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 personal data for
- If we did not collect data 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 is such instances.
Information Security & Technical and Organisational Measures
Cadman Fine Wines takes the privacy and security of individuals and their personal information very seriously, and are taking every reasonable measure and precaution to protect and secure the personal data that we process. We have dedicated 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: -
- Secure Sockets Layer (SSL) Certifications
- Transport Layer Security (TLS)
- Access Controls
- Password Policies
- Authentications and Restrictions
Cadman Fine Wines acknowledges its responsibility for promoting awareness of the GDPR across the organisation, assessing its GDPR readiness, identifying any gap areas and implementing the new policies, procedures, and measures.
We utilise a GDPR checklist designed by the Information Commissioner’s Office (ICO) to assess each business activity, function, and process and to ensure that we have a company-wide approach to meeting the new standards and requirements.
Cadman Fine Wines understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in preparations plans. We have implemented an employee training brief, which will be delivered to Cadman Fine Wines employees prior to May 25th 2018, and forms part of our induction process.
If you have any questions about our preparation for the GDPR, please contact Operations Director, Michael King.