GDPR – Our Commitment
Primary Intelligence 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 our obligations in updating and expanding this program to meet the demands of the GDPR.
Primary Intelligence is 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.
What information do we collect?
How do we use your information and what are your data subject rights?
Any of the information we collect from you may be used in one of the following ways:
- To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
- To administer a contest, promotion, survey, or other site feature
- To send periodic emails
- The email address you provide may be used to send you information, respond to inquiries, and/or other requests or questions.
You can easily manage your subscription preferences or opt-out of ALL communications by following this link: MANAGE YOUR EMAIL AND SUBSCRIPTION PREFERENCES
How We Have Prepared for the GDPR
Primary Intelligence already has a consistent level of data protection and security across our organization, however it is our aim to be fully compliant with the GDPR. Our preparation included: –
- Policies & Procedures – We have reviewed our current 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 Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimization’ 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 timeframes and notification responsibilities.
- 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.
- International Data Transfers & Third-Party Disclosures – where Primary Intelligence 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 as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict 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 (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 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 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.
- 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.
- 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.
- Processor Agreements – where we use any third-party to process personal information on our behalf (e. Payroll, Recruitment, Hosting, etc.), 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 organizational 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.
Information Security & Technical and Organizational Measures
Primary Intelligence 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 unauthorized access, alteration, disclosure or destruction and have several layers of security measures, including: –
Data Encryption by Default
Primary Intelligence automatically encrypts data before it is written to disk. The data is encrypted under the 256-bit Advanced Encryption Standard, and each encryption key is itself encrypted with a regularly rotated set of master keys.
Data is most vulnerable when it is in transit. For this reason, all communication to and from our servers is automatically encrypted using HTTPS/TLS to ensure customer security and confidentiality. Your data is hosted with a reputable hosting service and the security is certified by an independent third-party certificate provider.
Compliance and Certifications
Primary Intelligence’s cloud hosting provider uses servers that are certified using stringent compliance standards for data safety, privacy, and security. They fully comply with all PCI and ISO 27001 regulations compliance.
Primary Intelligence’s data servers are geographically located to minimize the effects of regional disruptions such as power outages and natural disasters. In the event of failure, the system automatically reroutes to another facility so that services can continue with minimal disruption.
Client Information Protection
Along with data transit security, Primary Intelligence is also concerned with internal security between clients. Because of this Primary Intelligence has developed a sophisticated security rights layer in TruVoice to maintain client privacy. No client has the ability to access another client’s data in any way for any purpose.
GDPR Roles and Employees
Primary Intelligence 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. We have implemented an employee training program specific to the which has been provided to employees prior to May 25th, 2018, and forms part of our induction and annual training program.
If you have any questions about our GDPR compliance, please contact [email protected].