Name of company
70 Bay Avenue
Bilston WV14 0TT
Tel: 7845848039 7845848039
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.
NAS Catering (‘we’ or ‘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 recognise our obligations in
updating and expanding this program to meet the demands of the GDPR and the [UK’s Data Protection Bill/insert relevant country DP law].
NAS Catering 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.
How We are Preparing for the
NAS Catering 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 by 25th May 2018. Our preparation includes:
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/implementing new] 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
- 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.
- International Data Transfers &
Third-Party Disclosures – where [insert organisation name] 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.
- 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. Our new 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.
- Legal Basis for
Processing - 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.
Notice/Policy – we [have revised/are revising] 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.
Consent - we [have revised/are revising] 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.
Marketing - we [have revised/are revising] 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. 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
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.
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’s right to access any personal information that
NAS Catering processes about them and to request information about: -
- What personal data we hold
- The purposes of the
- The categories of personal
- 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
NAS Catering 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, password policy, encryptions, pseudonymisation, practices, restriction,
IT, authentication etc provided though recognized third party organisations who have the skills and expertise as well as there own GDPR governance.
GDPR Roles and
NAS Catering have designated Neil
Snook as our [Data Protection Officer (DPO)/Appointed Person] 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.
NAS Catering 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 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.
If you have any questions about our preparation for the GDPR, please contact [Data Protection
Officer (DPO)/Appointed Person].