The EU General Data Protection Regulation (“GDPR”) came into force across the European Union on 25th May 2018 and brought with it the most significant changes to data protection law in two decades.
The new Regulation standardises data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
Codex Integrity Limited (‘Codex’ ‘we’, ‘us’ or ‘our’) are 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. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognised our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill.
Codex are dedicated to safeguarding the personal information under our remit and developed a data protection regime that is effective, fit for purpose and demonstrated an understanding of, and appreciation for the new Regulation. Our achieved objectives for GDPR compliance are summarised in this statement and included the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
Codex act as data controllers of our own employee data and business CRM data regarding contacts and clients and as data processors for the services that we provide.
We already have a consistent level of data protection and security for employees, customers, suppliers and 3rd parties across our organisation, and have actively taken the necessary steps for GDPR compliance. These steps include, but are not limited to: –
Information Audit – carried 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 – the revision of and implementation of new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: –
Legal Basis for Processing – we have reviewed all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to.
Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process as a data controller 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 have revised our mechanisms where we obtain consent for 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.
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 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 and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements.
Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have in place relevant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.
Special Categories Data – where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions 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.
Codex take 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.
Codex have designated the HSEQ Advisor as our Appointed Person with regard to the new data protection regulation. The Appointed Person along with our HR function and induction process are responsible for promoting awareness of the GDPR across the organisation, as well as ensuring that policies and procedures are adhered to and reviewed on a regular basis to ensure ongoing compliance.
Codex understand that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program which is provided to all employees and forms part of our induction and annual training program.
If you have any questions about our preparation for the GDPR, please contact us at firstname.lastname@example.org