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GDPR Compliance Statement – Prepared 11/05/2018
(Statement on behalf of Euro Soccer Company, a division of M3C Sports)
The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings 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.
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.
M3C Sports 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 recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill.
M3C Sports 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. We aim to be as transparent as possible, so if you have any questions, please do not hesitate to contact us.
How We are Preparing for the GDPR
M3C Sports already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR. To do so we have undertaken the following preparation:
- 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 - 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 reviewed 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 erasure 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. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow. Web data breaches are reported to the ICO within 72 hours and all parties involved.
- International Data Transfers & Third-Party Disclosures – we do not share data with any Third party or International entities for marketing purposes. Should M3C Sports choose to do so our procedures would include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules. We will 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. We do however require the sharing of data for online orders with web hosts Wida Group to ensure the running of the website.
- Subject Access Request (SAR) – our SAR procedure means that you as an individual can request what information we (M3C Sports) have collated for you as an individual. The provision is free of charge and enables you the right to confirm that all of our data processing are compliant, consistent and adequate within a 30-day period.
- 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. 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 amended 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 have revised 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 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.
- Direct Marketing – we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions on online orders; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials. As an individual you still have the ability to verbally opt in to our marketing communications – this record will then be kept as evidence.
- 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. 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, Recruitment, Hosting etc), we have drafted 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.
- 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.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide the individual with the option 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 Organisational Measures
M3C Sports 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, practices and restrictive measures.
Data Storage Examples:
Customer details when ordering goods, (online or direct i.e. in shop, via email, in person) including; name, organisation name, address, email address, contact number
- Stored for: order liaison – quick communications/updates
Customer details when requesting quotations or competition prizes including; name, organisation name, address, email address, contact number
- Stored for: potential order liaison and delivery updates
NEW Email addresses on dedicated secure spreadsheets and mailing accounts (i.e. Mail Chimp) when the customer agrees to receive marketing communications.
- Stored for: marketing purposes - if opted in
- We have recently emailed all contacts on the current lists asking for permission to continue using the said practices and provided an option to unsubscribe (May 2018)
- Customer information obtained from will be stored for up to an infinite time unless the individual has requested the removal of such details.
- It is likely that after a period of 5 years without contact M3C Sports will remove and destroy this data.
All other customer details when an individual has requested to be added to marketing communications (this can be through various sources - i.e. tournament stands, social media, in person)
Online customer details are stored on secure servers based in the UK which are backed up daily. This is hosted by Wida Group and security measures are provided by UK Fast. Stringent tests are regularly undertaken and the servers have been independently tested for added security. The data can be accessed by both parties above but is permission only for authorised personnel. A full policy can be provided on behalf of Wida Group on request.
Data Storage Examples – what we won’t store:
Customer bank details after a transaction has taken place. This will be safely destroyed immediately after.
Customer email addresses for marketing communications (i.e. on marketing lists) if the customer has not opted in to marketing promotions.
Customer order details if the individual has requested for these to be removed once the order has been processed.
GDPR Roles and Employees
M3C Sports have designated Jordan Ruck 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 are 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.
M3C Sports understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and has involved our employees in our preparation plans. We have implemented an employee training program specific to the which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.
M3C Sports aim to be transparent with all data handled and every customer retains the option for their details to be removed at any time. You can do this by contact us on 01332 666 595 or emailing email@example.com
Should any individual wish to lodge a complaint we encourage the issue to be dealt with our chief data protection officer (details below).
If for any reason you feel your issues have not been resolved after contacting the officer then you maintain the right to raise a complaint to a supervisory authority.
If you have any questions about our preparation for the GDPR or wish to enquire about how your information is stored, please contact Jordan Ruck, firstname.lastname@example.org, 01332 666 595.