PRIVACY / GDPR STATEMENT
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The materials contained on this website are provided for general information only and do not constitute any form of advice. Ashton Pitt Ltd assumes no responsibility for the accuracy of any particular statement and accepts no liability for any loss or damage which may arise from reliance on the information contained on this site. By providing links to other websites, Ashton Pitt Ltd does not guarantee, approve or endorse the information or products available at these websites, nor does a link indicate any association with or endorsement by the linked site to Ashton Pitt Ltd.
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The EU General Data Protection Regulation (“GDPR”) came into force on 25 May 2018.
The new Regulation aims to standardize data protection laws and processing across the EU, giving people greater rights to access and control their personal information.
Ashton Pitt Ltd is committed to ensuring the protection of all personal information that we hold, and to providing and protecting all such data. We recognize our obligations in updating and expanding this program to meet the requirements of GDPR.
Ashton Pitt Ltd is dedicated to safeguarding the personal information under our control and in maintaining a system that meets our obligations under the new regulations. Our practice is summarised below.
How We Prepared for GDPR
Ashton Pitt Ltd already has a consistent level of data protection and security across our organization, but we have introduced new measures to ensure compliance.
We carried out an audit of information previously held and ensured that it was compliant with the new regulations.
Policies and Procedures
We have revised data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
Our main policy and procedure document for data protection has been revised 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 and the rights of individuals.
Data Retention and 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 in accordance with our obligations. We have procedures in place to meet the new “Right to Erasure” obligation.
Our procedures ensure that we have safeguards in place to identify, assess, investigate, and report any personal data breach as early as possible. Our procedures have been explained to all employees.
International Data Transfers and Third-Party Disclosures
Where Ashton Pitt Ltd stores or transfers personal information outside the EU, we have robust procedures in place to secure the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as binding rules, or standard data protection clauses for those countries without.
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
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, whom the information is disclosed to and what safeguarding measures are in place to protect their information.
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 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 Protection Impact Assessments (DPIA)
Where we process personal information that is considered high risk, we have developed stringent procedures 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).
Where we use any third party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting, etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they meet and understand their/our GDPR obligations.
Data Subject Rights
We provide easy-to-access information via [our website, in the office, during induction, etc] of an individual’s right to access any personal information that [Insert Organization Name] processes about them and to request information about:
1) what personal data we hold about them
2) the purposes of the processing
3) the categories of personal data concerned
4) the recipients to whom the personal data has/will be disclosed
5) how long we intend to store your personal data for
6) if we did not collect the data directly from them, information about the source
7) the right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
the right to request the 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
8) the right to lodge a complaint or seek judicial remedy and whom to contact in such instances.
Information Security and Technical and Organisational Measures
Ashton Pitt Ltd takes the privacy and security of individuals and their personal information very seriously and takes every reasonable measure 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.
GDPR Roles and Employees
Ashton Pitt Ltd has designated Chris Pitt as our [Data Protection Officer (DPO)] and has appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team is responsible for promoting awareness of the GDPR across the organization, assessing our GDPR compliance, identifying any gap areas, and implementing new policies, procedures, and measures.
Ashton Pitt Ltd understands that continuous employee awareness and understanding is vital to continued compliance with the GDPR and have involved our employees in our preparation plans.
If you have any questions about our GDPR compliance policies, please contact Chris Pitt (MD) – [Data Protection Officer (DPO)].
Last reviewed 13 March 2023