Before we dive right in...
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Our preparation includes:
- Policies & Procedures – we are revising data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
- Data Protection – our main policy and procedure document for data protection has been overhauled 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. In addition, Data Talks utilizes Amazon Web Services (AWS) where our client data resides. Certifications and audit reports for AWS are:
- Data Retention & Erasure – our retention policy and schedule ensure that we meet the ‘data minimization’ and ‘storage limitation’ principles and that personal information is stored, archived, and destroyed compliantly and ethically. For each customer to Data Talks we have dedicated erasure procedures in place to meet the ‘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. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow. For customers that require even more sophisticated and automated- and proactive inspection for security risks according to their needs Data Talks can offer Machine Learning based services.
- International Data Transfers & Third-Party Disclosures – All data Data Talks collects is stored electronically in Ireland and dependent on services used in Germany, Europe on the Amazon Web Services infrastructure. Our application servers and database servers run inside an Amazon VPC, Virtual Private Cloud. The database containing raw data on digital behavior, usage, or other customer data is only accessible from the application servers and no outside sources are allowed to connect to the database. If Data Talks’ customers need to store or transfer 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.
- Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge to our customers. 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.
- Information Audits
- Internal audit – we are yearly 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. Our Data Catalogue enables us with Data Lineage in our data to speed up manual work.
- Legal Basis for Processing – we are together with our customers 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.
- 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 assessment templates for carrying out impact assessments together with our customers to 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).
- Privacy Notice/Policy – our Privacy Notice(s) comply with GDPR and expects that our customers ensure (as Data Controller) 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 – 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. The consent levels are together with our customers agreed on and Data Talks are responsible for implementing the consent levels. If a customer has a Consent Management solution Data Talks have integration mechanisms to receive the right consent along with time and date records from a Data Subject.
- Direct Marketing – Data Talks CDP includes clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
- Processor Agreements – as Data Talks are a Data Processor we expect to sign a Processor- and due diligence agreements with our customers for ensuring that they meet and understand our/their GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organizational measures in place, and compliance with the GDPR.
- Special Categories Data – Data Talks tries not to obtain and process any special category information. If it is required by our customers we do so in complete compliance with the Article 9 requirements and have high-level encryption and anonymization procedures 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.
If you have any questions on the above, we would be glad to discuss these further with you.