If you follow the ICO’s 12 point GDPR plan which we have explained in more detail at one of our previous articles ‘GDPR and avoiding a fine’, you will know you need to consider what personal data you hold and how you keep it secure.
Breaches by individuals can attract not just fines but criminal convictions as we saw recently when a recruitment manager who sent out 26 CVs to an external recruitment agency without consent from the data subjects was prosecuted at Birmingham magistrates court under Section 55 of the Data Protection Act. He pleaded guilty and picked up a £994 fine (including costs and a victim surcharge).
If you and your staff want to avoid such prosecution, you do need to make sure you have systems in place together with a good understanding of how to treat people’s personal data.
Simple and practical actions could include moving filing cabinets of customer invoices to a locked room where people cannot wander in and pick out files, getting staff to sign regular memos reminding them not to leave their work ipad unattended on a desk in a customer area and making sure any third party information processors are fully aware of the GDPR.
Start talking to any parties who hold or process data for you as if you give them personal data, the onus is on you to ensure they keep that data secure and only use it for purposes for which consent has been freely given. Some third party organisations are already getting on board, for example, Dealtrak who provide a Platform for finance applications, have said they are working towards ISO27001 qualification which is part of the ISO27000 family which sets international standards for keeping information assets secure.
Who are your data processors and controllers and what are they doing to comply?