The EU General Data Protection Regulation (GDPR) came into force across the European Union on 25th May 2018 and making significant changes
to data protection law, Â Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the needs 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.
Incr-edibles.co.uk (we or us or our) 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 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 and the United Kingdoms Data Protection Bill/United Kingdoms DP law
Incr-edibles.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.
Incr-edibles.co.uk already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant
with the GDPR by 25th May 2018. Our preparation includes:
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 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 subjects 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.
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.
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.
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 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 of an individuals right to access any personal information that Incr-edibles.co.uk processes about them and to request
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
Incr-edibles.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, including:
SSL, access controls, password policy, encryptions, pseudonymisation, practices, restriction, IT, authentication.
GDPR Roles and Employees
Incr-edibles.co.uk have designated Gordon Stark as our Appointed Person and have appointed a data privacy team to develop and implement our
roadmap for complying with the new data protection Regulation. The team are responsible for promoting awareness of the GDPR across the
organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
Incr-edibles.co.uk understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR. We have
implemented an employee training program specific to GDPR which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.
If you have any questions about our preparation for the GDPR, please contact Gordon Stark