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.
TLB Medicals Limited 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 recognise the requirement and importance of updating and expanding this program to meet the demands of the GDPR.
TLB Medicals Limited is dedicated to safeguarding the personal information under our remit and to developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation for the GDPR has been summarised in this statement and includes the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How We Have Prepared for the GDPR
- 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/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 individuals.
- 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 possibility. Our procedures are robust and have been disseminated to all employees, who are aware of the reporting lines and steps to follow.
- Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 1-month 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 are also maintaining records of our processing activities, ensuring that our obligations under Article 30 of the GDPR are met.
- Privacy Notice/Policy – 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.
- Processor Agreements – where we use any third-party to process personal information on our behalf 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.
Data Subject Rights
In addition to the policies and procedures mentioned above, individuals can enforce their data protection rights to query any personal information that TLB Medicals Limited 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
- The source of the data
Information Security & Technical and Organisational Measures,
TLB Medicals Limited takes the privacy and security of individuals and their personal information very seriously and are taking every reasonable measure and precaution to protect and secure the personal data that we process. We have dedicated 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.