THE GDPR (GENERAL DATA PROTECTION REGULATION)
The ‘General Data Protection Regulation’ (GDPR) is a piece of European data protection legislation designed to replace and strengthen the ‘1995 EU Data Protection Directive’ as well as unify these standards across the European Union.
The regulation aims to give consumers greater control over their personal data. It does this by increasing fines for companies that do not take the security of their customers data seriously, up to 20 million euros or 4% of turnover, as well as increasing consumers rights to access the data companies hold on them.
The GDPR became law on 25th May, 2018 and applies to any company who stores or processes the personal data of an EU citizen.
How this affects you?
When you use our service, we store your personal data on our servers. Doing so allows us to operate our website, issue you documentation for your journey and ensure your travel runs smoothly. This classes us, Airport Collections.net, as a ‘data controller’ and a ‘data processor’, you as a customer or passenger of Airport Collections.net are a ‘data subject’, although you may also be acting as a ‘data controller’ especially if you are booking on behalf of someone else. As a data controller, you may need to take steps yourself in order to comply with GDPR requirements.
As a data controller, you should ensure you’re compliant with the GDPR. We recommend you contact a legal professional to find out how the GDPR legislation will affect your organisation. The ICO recommends taking these 12 steps.
- Awareness: You should make sure that decision makers and key people in your organisation are aware that the law is changing to the GDPR. They need to appreciate the impact this is likely to have.
- Information you hold: You should document what personal data you hold, where it came from and who you share it with. You may need to organise an information audit.
- Communicating privacy information: You should review your current privacy notices and put a plan in place for making any necessary changes in time for GDPR implementation.
- Individuals’ rights: You should check your procedures to ensure they cover all the rights individuals have, including how you would delete personal data or provide data electronically and in a commonly used format.
- Subject access requests: You should update your procedures and plan how you will handle requests within the new timescales and provide any additional information.
- Lawful basis for processing personal data: You should identify the lawful basis for your processing activity in the GDPR, document it and update your privacy notice to explain it.
- Consent: You should review how you seek, record and manage consent and whether you need to make any changes. Refresh existing consents now if they don’t meet the GDPR standard.
- Children: You should start thinking now about whether you need to put systems in place to verify individuals’ ages and to obtain parental or guardian consent for any data processing activity.
- Data breaches: You should make sure you have the right procedures in place to detect, report and investigate a personal data breach.
- Data Protection by Design and Data Protection Impact Assessments: You should familiarise yourself now with the ICO’s code of practice on Privacy Impact Assessments as well as the latest guidance from the Article 29 Working Party, and work out how and when to implement them in your organisation.
- Data Protection Officers: You should designate someone to take responsibility for data protection compliance and assess where this role will sit within your organisation’s structure and governance arrangements. You should consider whether you are required to formally designate a Data Protection Officer.
- International: If your organisation operates in more than one EU member state (ie you carry out cross-border processing), you should determine your lead data protection supervisory authority. Article 29 Working Party guidelines will help you do this.
What We’re Doing to be GDPR Compliant
Airport Collections.net takes data security seriously. We take many steps to protect your data, these include:
- Enforcing ‘HTTPS’ connections to our web servers.
- Running regular security scans on our network.
- Regular scheduled scans of all PC’s with heavy duty virus protection software.
- Keeping an inventory of all the personal data we store and ensuring we only collect data that is required to carry out the service.
- Maintaining a ‘Data Flow Map’ which lists where we store our data including any third parties that are involved.
- Regularly reviewing our Data Protection Policies and ensuring appropriate training is provided to employees.
- Training staff on the ‘Data Breach Protocol’ to ensure everyone knows what to do in the unlikely event of a data breach.
We have a handful of documents available for customers which should enhance your understanding of how we use your data.
The GDPR has expanded consumers right of access to their data, as well as the removal/deletion of records. There are however some legal limitations placed on us that could limit our ability to comply with your request. These include our licensing authority’s requirement that we store 1 year of full journey records or our obligation as a limited company to store accounting (transaction) records for 6 years from the end of the last company financial year they relate to.
Airport Collections.net is committed to being fully compliant with this regulation.