Data Protection & GDPR Actions By Educa
Overview & Educa Commitment
The EU General Data Protection Regulation (GDPR) is the most significant piece of European privacy legislation in the last twenty years. It takes effect on May 25, 2018. It strengthens the rights that EU individuals have over their data, creating a uniform data protection law across Europe.
More than that though, GDPR is becoming a privacy rights and data protection gold standard around the world, partly because anyone with a website is serving that website in Europe. And partly because it’s such a comprehensive policy.
Educa is committed to being GDPR compliant. We are adding procedures and systems to comply with applicable GDPR regulations as a “data processor.” We are also working with our customers, who are “data controllers,” to help them understand the GDPR standards.
Changes By Educa
Educa already has a consistent level of data protection and security across our organization, however it is our aim to be fully compliant with the GDPR. This 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 – Implementing new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
- Data Protection – our policy and procedure documents for data protection have been overhauled. Accountability and governance measures have been added to tighten security and data access.
- Data Retention & Erasure – we have updated our data retention policy to meet the ‘data minimization’ and ‘storage limitation’ principles that require companies to look for ways to minimize the holding of personal data as well as how it is stored, archived and destroyed compliantly and ethically. We have data deletion procedures in place to meet the new ‘Right to Erasure’ obligation, also called the “right to be forgotten” along with any exemptions, response timeframes and notification responsibilities.
- Data Breaches – our breach procedures ensure that we have safeguards and measures to identify, assess, investigate and report any personal data breach at the earliest possible time.
- Data Transfers & Third-Party Disclosures – where Educa 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.
- Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information by any individual, e.g., employees.
- 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.
- Obtaining Consent – we are reviewing 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 are also creating processes to record consent as well as providing a way for individuals to 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 and an unsubscribe option on subsequent marketing materials.
- 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 are developing procedures and assessment templates for carrying out impact assessments 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 – where we use any third-party to process personal information on our behalf (i.e., Payroll, Hosting etc), we have reviewed Processor Agreements to make sure they meet and understand their/our GDPR obligations.
- Special Categories Data — we do not obtain or process any special category information — sensitive information such as race, politics, religion. However, if that were to change, we will do so in compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. 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, of an individual’s right to access any personal information that Educa 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 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 Organizational Measures
Educa 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 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, encryptions, pseudonymisation, practices, restriction, IT, authentication.
GDPR Roles and Employees
Educa has designated Aaron Rushworth as our Data Protection Officer (DPO)/Appointed Person to oversee the development and implementation our roadmap for complying with the new data protection Regulation. He is responsible for promoting awareness of the GDPR and data protection measures in general across the organization, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
Educa 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.
If you have any questions about our data protection policies or our GDPR compliance, please contact Aaron Rushworth.