GDPR Compliance

Statement for Crown Hygiene

Introduction

The EU General Data Protection Regulation (“GDPR”) Regulation (EU) 2016/679 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. Founded on the fundamentals of privacy by design and a risk-based

approach, the GDPR has been designed to meet the requirements of the digital age.

The 21st Century brings with its broad 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.

Our Commitment

Crown Hygiene 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 the

requirement and importance of updating and expanding this to meet the demands of the GDPR.

Crown Hygiene are dedicated to safeguarding the personal information under our

remit and to developing a data protection regime that is effective, fit for purpose and demonstrates

an understanding of, and appreciation for the new Regulation. Our preparation plans for the GDPR

have been summarised in this statement and includes the development and implementation of new

data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing

compliance.

How We are Preparing for the GDPR

Crown Hygiene already has a consistent level of data protection and security across

our organisation however, it is our aim to be fully compliant with the GDPR by 25th May 2018. Our

preparation 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 - data protection policies and procedures to meet the requirements

and standards of the GDPR and any relevant data protection laws, including: -

o Data Protection – our main policy and procedure document for data protection has

been updated 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.

o Data Retention & Erasure – we have reviewed our retention requirements 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 systems 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.

o 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 possibility. Our procedures are robust and have been

disseminated to all employees, who are aware of the reporting lines and steps to

follow.

o Subject Access Request (SAR) – we have revised our SAR procedures to

accommodate the revised 1-month timeframe for providing the requested

information and for making this provision free of charge. Our new procedures

include verification of the data subject, what steps to take for processing an access

request, what exemptions apply and will ensure that communications with data

subjects are compliant, consistent and adequate.

o Privacy Policy – we have updated our Privacy Policy 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.

o Obtaining Consent - we reviewed 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 implemented processes for recording consent, making sure that we can

evidence an affirmative opt-in, and an easy way to withdraw consent at any time.

o Direct Marketing - we will ensure the wording and processes for direct marketing,

include clear opt-in mechanisms for marketing subscriptions; a clear notice and

method for opting out and providing unsubscribe features on any subsequent

marketing materials.

o 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 ongoing reviews of the service provided, the necessity of the

processing activity, the technical and organisational measures in place and

compliance with the GDPR.

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 at Head Office, located at Unit

27, Bolney Grange Business Park, Stairbridge Lane, Bolney, West Sussex RH17 5PB of an

individual’s right to access any personal information that Crown Hygiene 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 Organisational Measures

Crown Hygiene takes the privacy and security of individuals and their personal

information very seriously and are taking every reasonable measure and precaution to protect and

secure the personal data that we process. We have information security procedures in place to

protect personal information from unauthorised access, alteration, disclosure or destruction and

have several layers of security measures, including: -

o access controls,

o password policy,

o encryptions,

o access restriction,

o authentication

GDPR Roles and Employees

Crown Hygiene regularly reviews data privacy and continue to develop and implement

our compliance with the new data protection Regulation. Staff members 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.

We utilise a GDPR checklist designed by the ICO to assess each business activity, function and

process and to ensure that we have a company-wide approach to meeting the new standards and

requirements.

Crown Hygiene 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 ensured employees have been updated with GDPR regulations and this

will also form part of our employee induction program.

If you have any questions about our preparation for the GDPR, please contact us.

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