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In part two of this short and to the point series, let’s explore some of the GDPR nuts and bolts. Checkout the first part here.
Namely, have we got lawful basis for even storing our data and can we release it completely when requested? To robustly comply with the EU General Data Protection Regulation (GDPR), organisations must now be able to maintain and produce a wide range of documentation, on demand if needed.
All orderly organisations will already I have sure, identified if its lawful for our data being held and processed. However, how well documented is this? GDPR requires robust documentation covering how holding and process of our data is lawful. In addition, privacy notices need to reflect this too. Examine yours, how good is your documentation in this regard? Remember that responsibility for the documentation’s accuracy will generally be down to the designated data controller.
Documentation of consent, how it is being obtained from each data subject, where is the record of it, is very important. GDPR strengthens this aspect of data protection. In social housing, it is likely that at lettings or tenancy sign up, we already tick this box. We need to review if current procedures meet the GDPR standard, or if they need to be made more transparent or robust. Question how your organisation seeks, records and then manages consent. Where is this recorded, could it easily be audited?
For the above, its hoped that mainstream systems will be providing specific fields to record and audit where consent has been positively obtained. Use of UDF/UDE/ad-hoc fields, while undoubtedly working, will lead to non-standard approaches, even within the same social housing systems. Hopefully some approaches have already started to be described for future enhancements particularly for GDPR pressure points along the tenant lifecycle, in a release late in 2017, by your software provider/supplier, in time for GDPR.
At this point, its salient to say that you should not really be asking your software suppliers, "What are you doing about GDPR?". You should be asking, "How can I use features of your system/solution, to better implement and comply with GDPR, and how are you improving those?".
In addition, we need to be engaging with our contractors, partners and others, who we are supplying data to, for limited use. EG during the life of the issue of a reactive repair or Works Order. How can we educate and 'ripple down' a GDPR culture to them too? Consider special workshops or briefing sessions with your contractors and vendors.
You can find numerous training organisations that have sprung up, to provide 'documentation packs' and the like, supporting this. Truth is, you can probably sort it easily in less than an afternoon, yourself. After all, a lot of that 'documentation' will only set you off on the road to getting this stuff in place.
Information regarding children, now may need additional consent of parents or guardians. If not already in place, possibly systems to verify ages must be put in place.
Once all the above is in place, how robust are our systems and procedures for responding to ‘Subject Access Requests’? What places and system applications may be the sources, to satisfy a subject access request? Certainly, main housing management systems may be the primary source, but do not miss document management and other peripheral systems and applications. It’s time to think this all through now, be prepared (as Baden-Powell used to say).
- A quick recap on those essential compliance documents:
- (GDPR Article 13) - Statements of the information you collect and process, and the purpose for processing.
- (GDPR Article 7 & 8) - Records of consent from data subjects or relevant holder of parental responsibility.
- (GDPR Article 30) - Records of processing activities under your responsibility.
In the last and final blog, we will explore Data Breeches and Privacy Impact Assessments, including documented processes for protecting personal data, information security and cryptography policy, procedures, etc.Checkout the first part here.
Related Post: How much does each method of payment cost your organisation?
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(c) Tony Smith, Acutance Consulting www.acutanceconsulting.co.uk 07854-655009
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