The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on
25 th 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 21 st 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.
Code Software 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 UK’s Data Protection Bill.
Code Software 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 policies, procedures, controls and measures to ensure maximum and ongoing
How We are Preparing for the GDPR
Code Software 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 25 th May 2018:-
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.
- Policies & Procedures - Implementing 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 subject’s 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.
International Data Transfers & Third-Party Disclosures – where Code Software stores
or transfers personal information outside the EU, we have robust procedures and
safeguarding measures in place to secure, encrypt and maintain the integrity of the
data. Our procedures 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
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.
Legal Basis for Processing – where relevant we are implementing processing activities to
identify the legal basis for processing and ensuring that each basis is appropriate for the
activity it relates to. Where applicable, we also maintain records of our processing activities,
ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data
Protection Bill are met.
Privacy Notice/Policy – where relevant we are implementing 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 – where relevant we are revising 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 – Code Software do not and will not use any personal information for direct marketing purpose
Data Protection Impact Assessments (DPIA) – Code Software does not process personal information that is considered high risk or includes special category/criminal conviction data.
Processor Agreements – We do not use any third-parties to process personal information on our behalf
Special Categories Data - We do not obtain or process any special category information.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their
data protection rights, we can provide information of an individual’s right to access any personal
information that Code Software processes about them and to request information about: -
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
Code Software 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:
- Access controls;
- Password policy;
- Encrypted data transfer over SSL channels;
GDPR Roles and Employees
Code Software understands that continuous employee awareness and understanding is vital to the
continued compliance of the GDPR and have involved our employees in our preparation plans.
If you have any questions about our preparation for the GDPR, please contact Mark Armstrong who is Code Software’s appointed GDPR person / DPO.