With the new GDPR policy implementation date of 25th May 2018 rapidly approaching, businesses are taking necessary steps to ensure compliance.
The ICO (Information Commissioner's Office) has released a useful guide, to help organisations take the correct steps to take.
The guidance focuses on the following steps:
Awareness - Companies should make sure that decision-makers and key people in the organisation are aware that the law is changing to the GDPR. They also need to appreciate the impact it is likely to have.
Information held - It should be documented in all the personal data that the organisation holds, where it came from and who you share it with. This may mean that you need to organise an information audit.
Communicating privacy information - You should review your current privacy notices and put a plan in place for making any necessary changes in time for GDPR implementation.
Individuals' rights - Procedures should be checked to ensure they cover all the rights individuals have, including how you would delete personal data or provide data electronically and in a commonly used format.
Subject Access Requests - Procedures should be updated and planned to handle requests within the new timescales and provide any additional information.
The Lawful basis for processing personal data - You should identify the lawful basis for your processing activity in the GDPR, document it and update your privacy notice to explain it.
Consent - You should review how you see, record and manage consent and whether you need to make any changes. Refresh existing consents now if they don't meet GDPR standards.
Children - You should start thinking about whether you need to put systems in place to verify individuals' ages and to obtain parental or guardian consent for any data processing activity.
Data Breaches - You should make sure you have the right procedures in place to detect, report and investigate a personal data breach.
Data Protection by Design and Data Protection Impact Assessments - You should familiarise yourself with the ICO's code of practice on Privacy Impact Assessments as well as the latest guidance from the Article 29 Working Party, and work out how and when to implement them into your organisation.
Data Protection Officers - You should designate someone to take responsibility for data protection compliance and assess where this role will sit within your organisation's structure and governance arrangements. You should consider whether you are required to formally designate a Data Protection Officer.
International - If your organisation operates in more than one EU member state (i.e. you carry out cross-border processing), you should determine your lead data protection supervisory authority. Article 29 Working Party guidelines will help you do this.
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