Privacy & GDPR
Introduction
The EU General Data Protection Regulation ("GDPR") came into force on 25 May 2018.
The new Regulation aims to standardise data protection laws and processing across the EU, giving people greater rights to access and control their personal information.
Our Commitment
Orkestro are committed to ensuring protection of all personal information that we hold, and to provide transparency on the steps we take to protect all such data. We recognise our obligations in updating and expanding this program to meet the requirements of GDPR.
Orkestro are dedicated to safeguarding the personal information under our control and in maintaining a system that meets our obligations under the new regulations. Our practice is summarised below.
How We Satisfy GDPR
To that end, Orkestro worked with third party data protection consultants to complete a data mapping and gap analysis exercise in relation to its data processing activities.
Following this, Orkestro has taken steps to ensure GDPR compliance which include:
Beyond the above, all staff are receiving annual data protection and information security training so that they are aware of their responsibilities under the UK GDPR.
Orkestro has a consistent level of data protection and security across our organisation, but we have introduced new measures to ensure compliance.
Data Subject Rights
We provide easy-to-access information via email request of an individual's right to access any personal information that Orkestro processes about them and to request information about:
Information Security and Technical and Organisational Measures
Orkestro takes the privacy and security of individuals and their personal information very seriously and takes every reasonable measure 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.
GDPR Roles and Employees
Orkestro have designated [insert DPO/lead name] as our Data Protection Officer, who is responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR compliance, identifying any gap areas and implementing the new policies, procedures and measures.
Orkestro 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.
If you have any questions about our GDPR compliance policies, please contact us at info@orkestro.com
Last reviewed 28 April 2021
Introduction
The EU General Data Protection Regulation ("GDPR") came into force on 25 May 2018.
The new Regulation aims to standardise data protection laws and processing across the EU, giving people greater rights to access and control their personal information.
Our Commitment
Orkestro are committed to ensuring protection of all personal information that we hold, and to provide transparency on the steps we take to protect all such data. We recognise our obligations in updating and expanding this program to meet the requirements of GDPR.
Orkestro are dedicated to safeguarding the personal information under our control and in maintaining a system that meets our obligations under the new regulations. Our practice is summarised below.
How We Satisfy GDPR
To that end, Orkestro worked with third party data protection consultants to complete a data mapping and gap analysis exercise in relation to its data processing activities.
Following this, Orkestro has taken steps to ensure GDPR compliance which include:
- implementing a new suite of internal data protection policies and procedures;
- updating our merchant and fleet agreements to include appropriate data protection terms (in accordance with UK GDPR requirements);
- updating website privacy and cookie policies;
- implementing a supplier due diligence programme to ensure that any service providers engaged to process personal data on its behalf have provided sufficient guarantees to implement appropriate technical and organisational measures;
- updating our information security policies and framework to meet GDPR requirements.
Beyond the above, all staff are receiving annual data protection and information security training so that they are aware of their responsibilities under the UK GDPR.
Orkestro has a consistent level of data protection and security across our organisation, but we have introduced new measures to ensure compliance.
- Policies and Procedures — we have revised 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 revised 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 and the rights of individuals.
- Data Retention and 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 in accordance with our obligations. We have documented policies to meet the new "Right to Erasure" obligation.
- Data Breaches - our procedures ensure that we have safeguards in place to identify, assess, investigate and report any personal data breach as early as possible.
- International Data - all our data is stored within the EU and we have robust procedures in place to secure the integrity of the data.
- 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
- Data Protection - our main policy and procedure document for data protection has been revised 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 and the rights of individuals.
- Privacy Notice/Policy - we have revised 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
- Data Protection Impact Assessments (DPIA) - where we process personal information that is considered high risk, we have developed procedures for carrying out impact assessments that comply fully with the GDPR's Article 35 requirements. We have documented processes that record each assessment 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 (ie Payroll, Recruitment, Hosting, etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they meet and understand their/our GDPR obligations.
Data Subject Rights
We provide easy-to-access information via email request of an individual's right to access any personal information that Orkestro 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 and Technical and Organisational Measures
Orkestro takes the privacy and security of individuals and their personal information very seriously and takes every reasonable measure 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.
GDPR Roles and Employees
Orkestro have designated [insert DPO/lead name] as our Data Protection Officer, who is responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR compliance, identifying any gap areas and implementing the new policies, procedures and measures.
Orkestro 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.
If you have any questions about our GDPR compliance policies, please contact us at info@orkestro.com
Last reviewed 28 April 2021
Orkestro is a Limited Company registered in
England and Wales (No. 10213640)
England and Wales (No. 10213640)
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