GDPR Compliance Statement
The EU General Data Protection Regulation (“GDPR”) came 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.
Fusion LX 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 recognise our obligations to meet the demands of the GDPR and the UK’s Data Protection Bill.
Fusion LX are dedicated to safeguarding personal information through a data protection regime that is effective, fit for purpose and demonstrates an understanding of the new regulation. Our commitment to GDPR compliance has been summarised in this statement.
Compliance with the GDPR
Fusion LX have a consistent level of data protection and security across our organisation, and are fully compliant with the GDPR. This is demonstrated through:
• Policies & Procedures – our data protection policies and procedures meet the requirements and standards of the GDPR and any relevant data protection laws, including:
· Data Protection – our data protection policy meets 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.
· Data Retention & Erasure – we ensure that we meet the ‘storage limitation’ and ‘data minimisation’ principles and that personal information is stored, archived and destroyed compliantly. We also 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 – we have measures in place to identify, assess, investigate and report any personal data breach within the required timeframe.
· International Data Transfers & Third-Party Disclosures – where Fusion LX stores or transfers personal information outside the EU, we have safeguarding measures in place to secure, encrypt and maintain the integrity of the data. We ensure that any third party to whom data is disclosed is GDPR compliant.
· Subject Access Request (SAR) – we are aware of our responsibility to meet the new 30-day timeframe for responses. Our procedures detail how to verify the data subject, what steps to take for processing an access request, and what exemptions apply.
· Legal Basis for Processing – we ensure that our basis for processing data is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities.
· Obtaining Consent - our consent mechanisms for obtaining personal data ensure that individuals understand what they are providing, why and how we use it, and give clearly defined ways to consent to us processing their information. We have a simple process to withdraw consent at any time.
· Direct Marketing - we use clear opt-in mechanisms for marketing subscriptions and provide clear unsubscribe features on all marketing materials.
· Data Protection Impact Assessments – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data, we comply fully with the GDPR’s Article 35 requirements.
· Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment etc), we have due diligence procedures for ensuring that they meet their GDPR obligations.
· Special Categories Data - where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements. Special category data is only processed where necessary and 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, we provide easy to access information via our website of an individual’s right to access any personal information that Fusion LX 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 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
Fusion LX 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 procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction.
GDPR Roles and Employees
Fusion LX understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR. All employees are aware of their personal obligation to comply with our data protection policies and procedures.