How We Have Prepared for the GDPR (Updated 29th November 2018)
PALS already have a consistent level of data protection and security across our partnership, however it is our aim to be fully compliant with the GDPR . Our preparation includes: –
- Policies & Procedures – 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 procedures 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 & 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. It is our revised policy to hold paper records on file in a secured cabinet for up to one year, with the exception of documents rewquired for tax purposes (e.g.receipts) which are held for 6 years. ,Electronic files are held for up to 6 years, after which they will be securely shredded/deleted.
- 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 employees, making them aware of the reporting lines and steps to follow. A record of any data breach will be made, and severe breaches of Data will be reported to the Data Commissioner.
- 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. 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 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 under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
- 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. 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.
- Data Protection Impact Assessments (DPIA) – 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 Article 35 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 the data subject(s).
- Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. cloud storage), 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. 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.
- Special Categories Data – where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed 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 that ensure individuals can enforce their data protection rights, we provide easy to access information via our website on an individual’s right to access any personal information that PALS 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 & Technical and Organisational Measures
PALS 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: –
Secured and updated firewall and anti-virus protections on all electronic devices.
- Password protected electronic devices.
Secured two-way authentication password system on cloud storage.
Ability to restrict data access to cloud storage in event of a breach.
Secured facilities and locked filing cabinets for all personal data.
GDPR Roles and Employees
PALS have designated Clinton Greenford as our Data Protection Officer (DPO). It is the role of the DPO to constantly monitor and update existing policies in accordance with the GDPR.
PALS understands that continuous awareness and understanding is vital to the continued compliance of the GDPR . In April 2017 Clinton Greenford attended a CMG Professional Trainign course in respect of ‘Preparing for a Data Protection Audit’.
If you have any questions about our preparation for the GDPR, please contact Clinton Greenford – 067 23923.
Privacy Statement for Psychological Assessments & Learning Solutions Psychological Assessments & Learning Solutions respects your privacy, and will not collect or record personal information about you from this website except when provided by you in respect of a requested task. This information will only be used for the purpose for which you intended. Any personal information which you volunteer will be treated in confidence applying reasonable standards of security, in accordance with the Data Protection Acts, 1988 and 2003. Any information which you provide will not be made available to third parties except in accordance with applicable laws and regulations. Collection and use of personal information
Psychological Assessments & Learning Solutions
Psychological Assessments & Learning Solutions collects information through this website from you in three ways:
- Via email
- Via web technical logs
- Via web forms
If you choose to contact Psychological Assessments & Learning Solutions Ltd via email, your details will be used only for the purposes for which you intended. When your email has been actioned, the original message will be retained by Psychological Assessments & Learning Solutions Ltd for a reasonable period of time. Note: Email is a not fully secure method of communication. If there are details which for any reason you do not wish to send via email, you should contact Psychological Assessments & Learning Solutions Ltd by post or telephone. Contact details may be found on the Contact Us page. If requested, we may send confidential reports by email as a secured and passworded pdf file, with password sent to a phone separately.
Web Technical Logs
Technical details of your visit to this website are recorded for business reasons. None of this information can be used to ascertain your identity. The following technical details are recorded:
- IP addresses
- Top-level domain names e.g. .ie, .com, .org, .net
- Web search terms
- Browser-type used and operating system
This technical information will only be used for statistical and other administrative purposes. Web Forms
If you wish to find out more about how Psychology Assessment & Learning Solutions Ltd’ manages issues of website data protection please contact us via email to firstname.lastname@example.org. If you wish to find out more about data protection in Ireland please visit the website of the Data Protection Commissioner.
Glossary of technical terms “Web browser”
The software used to view the web, e.g. Microsoft Internet Explorer, Netscape Navigator, Opera, Safari etc.
The identifying number of a computer directly connected to the internet expressed in “internet protocol” code e.g. 123.456.789.123. If you must “dial-up” to connect to the internet, the IP code will be the code of the computer you have dialled-into and not your computer.
Text-based pieces of information placed on your computer by a web site. Cookies are used by websites to record aspects of your visit.