Introduction

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.

Our Commitment to GDPR

EFM Global Logistics (EFM) 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.

EFM 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 regulations. 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

EFM 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.

Privacy Notice/Policy

We are revising our Privacy Policy 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 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.