The EU General Data Protection Regulation (\u201cGDPR\u201d) 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. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.<\/p>\n\n\n\n
The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.<\/p>\n\n\n\n
Law Business Research (\u2018LBR\u2019 or \u2018we\u2019 or \u2018us\u2019 or \u2018our\u2019) 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 have updated and expanded this program to meet the demands of the GDPR and the UK\u2019s Data Protection Bill.<\/p>\n\n\n\n
LBR are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.<\/p>\n\n\n\n
LBR has a consistent level of data protection and security across our organisation, and is fully compliant with GDPR regulation. This includes: \u2013<\/p>\n\n\n\n
\u2022 Information Audit \u2013 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.<\/p>\n\n\n\n
\u2022 Policies & Procedures \u2013 revising data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: \u2013<\/p>\n\n\n\n
\u2022 Data Protection \u2013 our main policy and procedure document for data protection meets 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.<\/p>\n\n\n\n
\u2022 Data Retention & Erasure \u2013 our retention policy and schedule ensure that we meet the \u2018data minimisation\u2019 and \u2018storage limitation\u2019 principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new \u2018Right to Erasure\u2019 obligation and are aware of when this and other data subject\u2019s rights apply; along with any exemptions, response timeframes and notification responsibilities.<\/p>\n\n\n\n
\u2022 Data Breaches \u2013 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. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.<\/p>\n\n\n\n
\u2022 International Data Transfers & Third-Party Disclosures \u2013 where LBR 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 without. We carry out strict due diligence checks 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.<\/p>\n\n\n\n
\u2022 Subject Access Request (SAR) \u2013 our SAR procedures accommodate the 30-day timeframe for providing the requested information and for making this provision free of charge. Our 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.<\/p>\n\n\n\n
\u2022 Legal Basis for Processing \u2013 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.<\/p>\n\n\n\n
\u2022 Privacy Notice\/Policy \u2013 our Privacy Notice(s) 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.<\/p>\n\n\n\n
\u2022 Direct Marketing \u2013 the wording and processes for direct marketing include a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.<\/p>\n\n\n\n
\u2022 Data Protection Impact Assessments (DPIA) \u2013 where we process personal information that is considered high risk, involves large scale processing or includes special category\/criminal conviction data; we have stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR\u2019s 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).<\/p>\n\n\n\n
\u2022 Processor Agreements \u2013 where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have compliant 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.<\/p>\n\n\n\n
\u2022 Special Categories Data \u2013 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.<\/p>\n\n\n\n
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, in the office, during induction etc of an individual\u2019s right to access any personal information that LBR processes about them and to request information about: \u2013<\/p>\n\n\n\n
\u2022 What personal data we hold about them
\u2022 The purposes of the processing
\u2022 The categories of personal data concerned
\u2022 The recipients to whom the personal data has\/will be disclosed
\u2022 How long we intend to store your personal data for
\u2022 If we did not collect the data directly from them, information about the source
\u2022 The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
\u2022 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
\u2022 The right to lodge a complaint or seek judicial remedy and who to contact in such instances<\/p>\n\n\n\n
LBR 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: \u2013<\/p>\n\n\n\n
\u2022 Encryption using certificates from trusted certificate authorities
\u2022 Security by design
\u2022 Edge and internal firewalls to segregate roles
\u2022 Segregation of datasets
\u2022 Physical and digital access controls
\u2022 A complex passphrase policy
\u2022 Offsite backups
\u2022 Regular patch cycle and reporting
\u2022 Regular penetration and vulnerability testing by external specialists<\/p>\n\n\n\n
LBR have a designated Data Protection Officer (DPO) to develop and implement our roadmap for complying with the new data protection Regulation. The DPO is responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.<\/p>\n\n\n\n
LBR 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. We have an employee GDPR training program which was provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.<\/p>\n\n\n\n