GDPR Compliance Statement
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 organisations that control or process relevant
personal data and introduces new rights and protections for EU data subjects. The GDPR applies to data 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. TouchStar 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. TouchStar 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:
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Customer Contracts: will address GDPR compliance.
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Policy Development: we will review/ refresh and develop our range of policies including (but not limited to) our Data Breach
Policy, Business Continuity Plans, DPO appointment, Subject Access Requests, Individuals Rights, ICO Good Practice
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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.
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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.
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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.
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Controls & Gap Analysis: running alongside the work already underway, we will be reviewing the controls in place, or required.
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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.
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Technology: we will be reviewing our technology platforms to analyse their operation, security, compliance in order to ensure
that they meet the standards we have laid down and identify any gaps and risks.
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Outbound Marketing: GDPR mandates that the processing of personal data can only be undertaken when at least one of
six criteria has been met. The most obvious choice for businesses already working with data is ‘legitimate interests’. The
legitimate interests basis has three elements: identify a legitimate interest; show that processing is necessary to achieve it;
and balance it against the individual’s interests, rights and freedoms. TouchStar operate exclusively within ‘niche’ vertical
sectors / industrial B-2-B markets. As such we acquire / build data for the sole purpose of highlighting the availability of our
data capture / mobile computing solutions and promoting industry best practice to individuals with a defined job function
operating within these sectors. We do not undertake mass / ‘spam’ broadcast marketing that targets non-relevant individuals
or organisations with irrelevant information. That said, TouchStar recognise that not all target contacts that are relevant
to it’s operations will wish to receive information on the organisation’s products and solutions. TouchStar provide an easy
‘one button’ unsubscribe process that enables email recipients to be automatically and permanently unsubscribed from its
master mailing database. Should recipients prefer to contact TouchStar directly via other means, such as email or letter, with
a request to be unsubscribed then these requests are processed within 24 hours and the requesting party notified directly
of the deletion of the data. TouchStar maintain a stance of ‘legitimate interest’ which has been ratified by external GDPR
consultants.
Our Data Protection Officer, our Senior Management Team and advisors will continue to monitor the programme up to the
target date in May 2018 and beyond.
Legitimate Interests and the Fair Processing of Data
HOW DO WE USE YOUR PERSONAL INFORMATION?
We may process your personal information for our legitimate business interests.e.g. direct marketing/network and information
systems security/data analytics/enhancing, modifying or improving ourservices/identifying usage trends/determining the
effectiveness of promotional campaigns and advertising.
THE LEGITIMATE INTERESTS GDPR CLAUSE
When analysing our compliance with GDPR legislation TouchStar has opted by the ‘Legitimate Interests’ clause of the legislation
to justify it’s data processing activities. “Legitimate Interests” means the interests of our company in conducting and managing
our business [to enable us to give you the best service/products and the best and most secure experience]. For example, we
have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing
that is tailored to your interests.
It can also apply to processing that is in your interests as well. For example, we may process your information to protect you
against fraud when transacting on our website, and to ensure our websites and systems are secure. When we process your
personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both
positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically
override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on
you (unless we have your consent or are otherwise required or permitted to by law).
PROCESSING ACTIVITY
The processing of your data is subject to the following activity. Data is acquired via listing building, list purchase, the completion
of web contact forms or the completion of exhibition enquiry cards. Touchstar marketing communication activity is focused
on broadcast email campaigns. For email broadcast purposes our email address will be added to our third party cloud-based
delivery system (SendInBlue). All other contact data (name, address, telephone number etc.) is not recorded or retained within
this system and is removed from other computer storage facilities (e.g. laptops or desktops). The SendInBlue system is used
exclusively to provide individuals with information relating to industry best practice, industry technological developments,
company product developments and enhancements, core sales messages. Your data is not subject to any form of additional
processing and is not shared with any third party. The SendInBlue servers are located within France and the organisation is itself
bound by GDPR regulations relating to data processing and security. Further information on SendInBlue’s compliance can be
found at www.sendinblue.com
You have the right to object to this processing if you wish and if you wish to do so please contact us at gdpr@touchstar.co.uk