GDPR Compliance / Commitment Statement
The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May, 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements 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 standardize data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
FlashParking 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. Even though we do not actively do business in the 28 European Union member countries, or target marketing efforts to individuals within the EU, we recognize our obligations in updating and expanding this program to meet the demands of the GDPR should we choose to expand our business footprint in the EU.
FlashParking is dedicated to safeguarding the personal information under our remit and in developing a data protection regimen 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 summarized 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.
How We Will Comply with the GDPR Upon Business/Marketing Expansion
FlashParking does not currently do business with entities in the 28 European Union countries, nor targets marketing activities or promotions to individuals within the EU, as well FlashParking already has a consistent level of data protection and security across our organization, it is our aim to be fully compliant with the GDPR standards, should we choose to expand our business footprint in the EU.
Our preparation includes:
- Information Audit – carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
- Digital Presence Audit – Marketing-wide brand audit to ensure that no current marketing activities or online presence targets EU member countries, thus requiring any immediate policy/process changes.
- Policies & Procedures – To be implemented upon business/marketing expansion into EU member countries – Should FlashParking choose to do business in, and market to individuals in EU member countries, data protection policies and procedures will be implemented 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 would be overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures would be put 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 – A data 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 would be implemented compliantly and ethically.
- Data Breaches – Breach procedures would be put in place to ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. These procedures would be disseminated to all employees, making them aware of the reporting lines and steps to follow.
- International Data Transfers & Third-Party Disclosures – where FlashParking would store or transfer personal information outside the EU, robust procedures and safeguarding measures would be ensured to secure, encrypt and maintain the integrity of the data. Those procedures would 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) – A comprehensive SAR procedure would be put in place to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge.
Privacy Notice/Policy – Should FlashParking choose to do business in, and market to individuals in EU member countries we would revise 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– Should FlashParking choose to do business in, and market to individuals in EU member countries, we would revise 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 would develop 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– Should FlashParking choose to do business in, and market to individuals in EU member countries we would revise and update 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– Should FlashParking choose to do business in, and market to individuals in EU member countries, and where we would use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we will draft compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations.
- Special Categories Data– Should FlashParking choose to do business in, and market to individuals in EU member countries, and where we would obtain and process any special category information, we will 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 FlashParking takes the privacy and security of individuals and their personal information very seriously and takes every reasonable measure and precaution to protect and secure the personal data that we process.
If you have any questions about our preparation for the GDPR
please contact 888-737-7465.
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