The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a privacy and data protection regulation in the European Union (EU) and will be enforceable from May 25 2018 and requires no enabling legislation so automatically becomes binding and applicable on that date.

The GDPR imposes new obligations on organizations that control or process relevant personal data and introduces new rights and protections for EU data subjects.

The GDPR applies to processing carried out by organisations operating within the EU. It also applies to organisations outside the EU that offer goods or services to individuals in the EU.

Six Degrees places a high importance on information security and within our Group we already comply with a number of standards that also focus on information data security including IS27001 and PCI-DSS.

Six Degrees will be complying with the GDPR as a processor and controller of data and have been planning and developing a programme of works which will deliver what is required by the legislation. This will involve working with our suppliers and partner organisations to ensure they can meet these obligations.

As we work towards compliance, we have engaged an external advisor to ensure we deliver best practice in compliance, and our programme up to May 2018 falls into these areas:

  • Customer Contracts: our Master Services Agreement already addresses GDPR compliance.
  • Policy Development: we will review/ refresh and develop our range of policies including (but not limited to) our 27001 Controls, Data Breach Policy, Business Continuity Plans, DPO appointment, Subject Access Requests, Individuals Rights, ICO Good Practice
  • Website Data Collection & Consent, Privacy Policy: we will provide an updated framework and privacy policy to incorporate the GDPR obligations. This will include legal framework gap analysis arising from the reviews we undertake as the plan progresses.
  • Data Impact Assessments & Data Inventory: we are already undertaking a systematic review of the data we store, manage, maintain, collect, process and control. This includes offline storage and paper records. Assessments of the data will review information flow, any data transfers, risk reviews, and structural position in relation to Lawfulness, Purpose, Minimisation, Accuracy, Consent, Limitation, Integrity & Confidentiality, Record Keeping and Accountability.
  • Training & Awareness: we will undertake training across the Group on the GDPR and its impact on the new policies, procedures, and responsibilities of staff & stakeholders in this new regime.
  • Controls & Gap Analysis: running alongside the work already underway, we will be reviewing the controls in place, or required.
  • Supplier & Partner relationships: where relevant and related, we will be using all reasonable endeavours to ensure that our third party and suppliers are complying with the GDPR.
  • Technology: we will be reviewing our technology platforms to review their operation, security, compliance in order to ensure that they meet the standards we have laid down and identify any gaps and risks.

Six Degrees Security Officer, our Senior Management Team and advisors will continue to monitor the programme up to the target date in May 2018 and beyond.