GDPR

GDPR Statement

Introduction

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. 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 standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.

Our Commitment

Haslemere Travel 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 an 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.

Haslemere Travel is 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 data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

How We are Preparing for the GDPR

Our preparation includes: –

• Formal GDPR Audit – this was carried out in November 2017 by external GDPR and data protection specialists – Databasix.  This company-wide information audit identified and assed what personal information is held by Haslemere Travel, where it comes from, how and why it is processed and if and to whom it is disclosed.
• Policies & Procedures – we will be updating data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: –

o 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.

o 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.

o 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.

o International Data Transfers & Third-Party Disclosures – For the purpose of facilitating overseas holidays Haslemere Travel will work with suppliers based both inside our outside of the EU.  Our suppliers may store or transfers personal information outside the EU, however we are dedicated to continually reviewing the companies with which we share personal data.

o Subject Access Request (SAR) – we will continue to ensure our SAR procedures provide the individual with clear, accurate and free information when requested. We will revise the policy to ensure this is done within the 40-day timeframe.

• Legal Basis for Processing – we are reviewing all 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 – we have revised our Privacy Policy 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.
• Legitimate Interest – Haslemere Travel will only use your data for the purpose of facilitating the holiday reservation or enquiry that you have made with the company or to provide you with holiday related news, offers, competitions and event information.  Legitimate interest is one of the lawful basis for processing personal data in line with the ‘lawfulness, fairness and transparency’ principle.
• Direct Marketing – we have revised the wording and processes for direct marketing.  All communications will have a clear notice and method for opting out or unsubscribing.
• Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. flight consolidators, tour operators, ground handlers etc.), we have drafted compliant Processor Agreements and due diligence procedures in our agency agreements to ensure that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.Data Subject RightsIn addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our website, via email upon request or over the telephone of an individual’s right to access any personal information that Haslemere Travel 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