The EU General Data Protection Regulation (“GDPR”) becomes effective on 25th May 2018 and ushers in significant changes to data protection law. Core-apps participates in some activities that may be subject to GDPR, and this document sets forth how Core-apps intends to implement and comply with GDPR.
Core-apps (hereinafter also referred to as “we” or “us” or “our”) is 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 in accordance with applicable laws. We have consistently implemented data protection programs that are robust and effective. However, we acknowledge our efforts to update and revise our data protection program to meet the requirements of the GDPR as well as the various applicable requirements of data protection laws in effect in the United States.
We are dedicated to safeguarding the personal information that we are entrusted with and to developing data protection practices that are effective and which demonstrate an understanding of all applicable legal requirements. A brief summary of our policies, procedures and objectives for GDPR compliance are summarized below.
How We are Preparing for the GDPR
Core-apps already has a consistent level of data protection and security across our organization. However, in order to achieve full compliance with the GDPR by 25th May 2018, we have taken the following steps:
- Information Audit – we are continuously monitoring and assessing 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 – we have revised our data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: –
- Data Protection – our primary policy and procedure document for data protection has been adjusted 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 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 and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated data destruction 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 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 possible time.
- International Data Transfers & Third-Party Disclosures – where Core-apps 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 not deemed adequate. We carry out strict quality control reviews with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
- Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information. 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 have revised 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 to be more transparent, 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.
- Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures that comply fully with the GDPR’s Article 35 requirements. We have implemented 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 – Core-apps does not enter into 3rd party processor agreements at this time.
- Special Categories Data – To the extent we obtain and process any special category information, we do so in compliance with the Article 9 requirements and have high-level encryption 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 our website and our mobile applications of an individual’s right to access any personal information that Core-apps processes about them and to request information about:
- What personal data we hold
- 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
- 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 make a complaint or seek a remedy and who to contact in such cases
Information Security & Technical and Organizational Measures
Core-apps takes the privacy and security of individuals and their personal information very seriously and take every commercially 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 unauthorized access, alteration, disclosure or destruction and have multiple layers of security measures, including but not limited to: SSL encryption, on-disk encryption, access control policies, redundant firewalls, and two factor authentication.
GDPR Roles and Employees
Core-apps has designated Jonathan Johnson as our Data Protection Officer (DPO) and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team is responsible for promoting awareness of the GDPR across the organization, assessing our GDPR readiness, identifying any gaps in compliance and implementing the new policies, procedures and measures.
Core-apps understands that continuous employee awareness and understanding is integral to the continued GDPR compliance. Therefore, we implemented an employee training program specific to the GDPR which will be provided to all employees prior to May 25th, 2018, and is integrated into our on-boarding and annual training programs.
If you have any questions about our preparation for the GDPR, please contact Core-apps CEO Jay Tokosch, jay [at] core-apps.com.