The EU General Data Protection Regulation (“GDPR”) came into force across the European Union on 25th May 2018 and brought with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the 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 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: 

LOGOS Development CIC 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. Our data protection approach /policies will be robust in design and effective it is approach, whilst being complaint with existing law and the data protection principles.  

LOGOS Development CIC are 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. 

LOGOS subscribes in full to the seven key GDPR principles: 

  • Lawfulness, fairness and transparency. 
  • Purpose limitation. 
  • Data minimisation. 
  • Accuracy. 
  • Storage limitation. 
  • Integrity and confidentiality (security) 
  • Accountability. 

Data Subject Rights:

In 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 of an individual’s right to access any personal information that LOGOS Development CIC process 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 

Policies and Procedures 

Data Protection – 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. 

Data Retention & Erasure – Our retention policy and schedule 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. 

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 volunteers, making them aware of the reporting lines and steps to follow. 

Subject Access Request (SAR) – Our SAR procedures accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate. 

Information Security & Technical and Organisational Measures 

LOGOS CIC takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: – 

  • SSL certification on all our website operations 
  • Access controls on all client information within the organisation. 
  • Mandatory GDPR training for all Executive Board Members and volunteers. 
  • Secure storage of all paper-based files and data. 
  • Secure confidential waste disposal procedures. 

GDPR Roles and Employees 

LOGOS Development CIC have designated Sonia Campbell, Company Secretary, as our Appointed Person. The Company Secretary is responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures. 

LOGOS Development CIC understands that continuous Board and volunteers awareness and understanding is vital to the continued compliance of the GDPR. We have implemented a volunteer training program that forms part of our induction and annual training program. 

If you have any questions about our preparation for the GDPR, please contact Sonia Campbell.