Learn more about how DecoNetwork collects and uses data and your rights as a DecoNetwork user.
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 standardize data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
DecoNetwork is 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 recognize our obligations in updating and expanding this program to meet the demands of the GDPR.
DecoNetwork is 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 GDPR
DecoNetwork already has a consistent level of data protection and security across our organization, 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 – 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, 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 relevant employees, making them aware of the reporting lines and steps to follow.
- International Data Transfers & Third-Party Disclosures – where DecoNetwork 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 third parties to whom authorised disclosure of personal information is taking to ensure these parties are also GDPR compliant.
- Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a what responses 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.
- Privacy Notice/Policy – we 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.
- Obtaining Consent – we 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.
- Direct Marketing – we 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 Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy access to information via the DecoNetwork framework of an individual’s personal information that DecoNetwork processes about them and to request information about:
- What personal data we hold about them
- The purposes of the processing
- The recipients to whom the personal data has/will be disclosed
- The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
- The right to request the 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
Facebook data in the form of images is used for the purpose of product decoration, on a user request basis only. These images are not stored in our database and are only kept when a customer decides to use the image in an order, hence converting the image into a design. Customers may delete these designs through the “customer management area > designs” if they were never used anywhere (i.e. not used in any completed order or decorated products). The step-by-step on how to delete the designs can be found here: Remove Social Media Designs
All Facebook data (images) are automatically deleted when a customer removes their account and unused data (not actually used as a decoration which is part of a completed order) is deleted after 60 days.
Furthermore, upon request via email to firstname.lastname@example.org all Facebook data, whether it is used in an order or otherwise, can be irrevocably removed from the platform.
Information Security & Technical Organisational Measures
DecoNetwork 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:
A brief description of DecoNetwork’s security practices can be found here.
How Does GDPR Affect Existing and New DecoNetwork Customers?
If you are an existing DecoNetwork customer, you will soon be asked to agree with our updated license agreement, which features the addition of clause 7.9 which relates to compliance and consent with the GDPR. Once you agree to the updated terms and conditions you can continue to operate DecoNetwork as before, however you should be aware that if you are handling the personal information of European citizens you must also comply with the requirements of the GDPR. If you are a new or prospective DecoNetwork customer, you must also agree to the same conditions of the updated license agreement, which is part of the initial sign up process.
GDPR Related Communications
If you have any questions or requests regarding DecoNetwork’s GDPR compliance, please forward them via email to email@example.com