GDPR COMPLIANCE STATEMENT
This is a statement of Data Protection Compliance adopted by Image Line nv.
The EU General Data Protection Regulation (“GDPR”) came into force across the European Union on 25th May 2018 and introduced significant changes to data protection law. Its purpose is to improve privacy and security for the users of online services and websites or where personal data is stored and accessible through online mechanisms.
The GDPR aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
We have always had a robust and effective data protection programs 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 UK’s Data Protection Bill (regardless of the UK’s decision to leave the EU).
We are dedicated to safeguarding the personal information of all people we interact with, by developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the GDPR regulation. Our preparation and objectives for GDPR compliance include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
As a business operation, Image Line needs to collect and use certain types of information about people with whom it deals in order to operate. This includes current, past and prospective employees, suppliers, clients/customers, partners, and others with whom it communicates. In addition, it may occasionally be required by law to collect and use certain types of information of this kind to comply with the requirements of government departments for business data, for example.
This personal information must be dealt with properly, however it is collected, recorded and used – whether on paper, in a computer, or recorded on other material.
We regard the lawful and correct treatment of personal information by Image Line nv as very important to successful operations, and to maintaining confidence between those with whom we deal and ourselves. We ensure that our organisation treats personal information lawfully and correctly.
To this end we fully endorse and adhere to the Principles of Data Protection, as enumerated in the Data Protection Act 1998 and the GDPR (General Data Protection Regulation).
Data protection principles
Personal data shall be processed fairly, lawfully and transparently, in particular, shall not be processed unless specific conditions are met.
Shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
Shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
Shall be accurate and, where necessary, kept up to date.
Shall not be kept for longer than is necessary for that purpose or those purposes.
Shall be processed in accordance with the rights of data subjects under the Act ; Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
Therefore, Image Line nv will, through appropriate management, ensure strict application of criteria and controls:
Observe fully conditions regarding the fair collection and use of information
Meet its legal obligations to specify the purposes for which information is used
Collect and process appropriate information, and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements
Ensure the quality of information used
Apply strict checks to determine the length of time information is held
Ensure that the rights of people about whom information is held, are able to be fully exercised under the Act. (These include: the right to be informed that processing is being undertaken, the right of access to one’s personal information, the right to prevent processing in certain circumstances and the right to correct, rectify, block or erase information which is regarded as wrong information.)
Take appropriate technical and organisational security measures to safeguard personal information
Ensure that personal information is not transferred outside the EU, without suitable safeguards.
In addition, Image Line will ensure that:
There is an individual with specific responsibility for data protection within the organisation
Everyone managing and handling personal information understands that they are contractually responsible for following good data protection practice
Everyone managing and handling personal information is appropriately trained to do so
Everyone managing and handling personal information is appropriately supervised
Anybody wanting to make enquiries about handling personal information knows what to do
Queries about handling personal information are promptly and courteously dealt with
Methods of handling personal information are clearly described
Methods of handling personal information are continuously assessed and evaluated
At no stage will we divulge to a third party any personal data relating to the Data Subject.
Data Subject Access requests (DSAR)
It is the right of an individual to request any “personal data” that an organization holds on them. This right is a principle of the current EU Directive 95/46/EC and is retained in the GDPR. It is designed to regulate the processing of information from which a living individual can be identified or singled out either from the information on its own or when combined with other information. There will be no fee charged for a Data Subject Access request and any request will be responded to within one month of receipt.
Data Subject Access requests should be directed to: firstname.lastname@example.org
Image Line nv, in line with the requirements in the GDPR, will report any data breach to the data protection commissioner, within 72 hours of becoming aware of any such breach and inform any affected individuals whose personal information may have been breached.