GDPR Statement

Introduction

The EU General Data Protection Regulation (GDPR) came into force across the European Union on 25th May 2018 and it 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.

Our commitment

Dancersbox.co.uk 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 programme in place which complies with existing laws and abides by the data protection principles. However, we recognise our obligations in updating and expanding this programme to meet the demands of the GDPR and the UK’s Data Protection Bill.

Dancersbox.co.uk 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 were prepared for the GDPR

Dancersbox.co.uk have a consistent level of data protection and security across our company, however it is our aim to be fully compliant with the GDPR.

Our preparation included: – 

• Information audit – carried out a company-wide information audit to identify and access what personal information we hold, where it comes from, how and why it is processed and if whom it is disclosed.
• Policies and procedures – revised data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws.
• Legal basis for processing – we have reviewed 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 of the data protection bill are met.
• Privacy notice/policy – we have revised our privacy notice to comply with 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 ensured 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.
• Direct marketing – we have revised 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 – 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 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 data subject.
• Processor agreement – where we use third-party to process personal information on our behalf, we are drafting compliant processor agreements and due diligence procedures for ensuring that they 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.
• 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 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 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 time-frames and notification responsibilities.
• Data breeches – our breech procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breech 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 and third-party disclosures – where dancersbox.co.uk 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 ad provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out 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 – 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 response templates to ensure that communications with data subjects are compliant, consistent and adequate.
• Special categories data – this is where we obtain and process any special category information, we do so in complete compliance with the requirements and have high-level encryption and protections on all such data. 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 that ensure individuals can enforce their data protection rights, we provide easy to access information via website of an individual’s right to access any personal information that dancersbox.co.uk processes about them and to request information about: – 

• what personal data we hold about them
• the purposes of the processing
• the categories of the personal data concerned
• the recipients to whom the personal data has/will be disclosed
• how long we intend to store your personal information for
• if we did not collect the data directly from them, information about the source, if available
• the rights to have incomplete or inaccurate data about them corrected or completes and the process for requesting this
• the right to request erasure of personal data 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 compliant or seek judicial remedy and who to contact in such instances

Information security and technical and organisational measures

Dancersbox.co.uk 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.

If you have any questions about our GDPR statement then please contact us: – dancersbox.co.uk

Allison, Andrea and Victoria
Dancers Box UK