Argon Electronics (UK) Ltd. is aware that the General Data Protection Regulation (GDPR) - which comes into force on 25th May 2018 - broadens the rights of individuals from those outlined in the Data Protection Act 1998. The new regulation ensures that data subjects are better able to understand, manage and control how their personal data is being processed by organisations.
This process looks at how we will respond to and act upon three of those rights specifically, in relation to the data processing we undertake for marketing purposes:
i) Right to be forgotten (aka Right to erasure):
Data subjects can request the deletion of their personal data, where there is “no compelling reason for its continued process” (i.e. this could be where the individual has withdrawn their consent, or their personal data is no longer relevant to what it was originally obtained for).
We can easily achieve this deletion from our marketing platform, HubSpot, which will remove the individual and all their related data from the system. We will communicate - within one business week - any request for deletion with Equinet, our marketing partner (and Data Processor), to ensure that any data related to the same individual might be removed from their data system also.
Conscious of the need to respond without “undue delay”, we are committed to actioning any such request within three weeks (21 days), which falls well within the stipulated one month under GDPR.ii) Right to access
The GDPR clarifies that the reason for allowing individuals to access their personal data is so that they are aware of and can verify the lawfulness of the processing (Recital 63). It is understood that in order to comply with this right to access Argon Electronics (UK) Ltd. must provide the individual requesting access to their data, both confirmation that their data is being processed and access to their personal data.
Again, conscious of the fact that the new Regulation states that information must be provided without delay and within at least one month of receiving the request, Argon Electronics (UK) Ltd. will seek to action any subject request for access within a 21-day time period.
We will ensure that the information is in a format that will be easy for that individual to use and understand (for example, we can download a .csv file exported straight from our marketing platform, HubSpot, which will detail all data related to a specific contact).
We understand that in most circumstances, organisations must provide subjects with a copy of the information they request free of charge. However, Argon Electronics (UK) Ltd. acknowledges that we are permitted to charge a “reasonable fee” (based on the administrative cost of providing the information) when a request is manifestly unfounded, excessive or repetitive.
iii) Right to data portability
Data subjects will have the right, from 25th May 2018, to demand a copy of their data in a common format (for example, .csv file) so that they might move it to another Data Controller of their choice.
We do not particularly anticipate many such requests under this right with regard to our marketing data processing, where they do arise though we will seek to comply similarly to the above. That is to say all information regarding a data subject will be exported from the HubSpot platform, again as a .csv file, and then transferred to the individual accordingly within the 21 day time period we aim to achieve.
Lastly, we are aware that there are, under GDPR, a number of other rights for individuals which we must comply with, including the Right to object, the Right to restriction of processing, and more. Argon Electronics (UK) Ltd. will respond to any requests made under these rights in a similarly timely and appropriate manner as for those outlined here.