GDPR - anyone working in this area?

GDPR - anyone working in this area?

Author
Discussion

plasticpig

12,932 posts

226 months

Wednesday 25th October 2017
quotequote all
DELETED: Comment made by a member who's account has been deleted.
I understand that they are included in GDPR. Hadn't seen the guidance though and that is interesting.

nikaiyo2

4,757 posts

196 months

Wednesday 25th October 2017
quotequote all
How random I had never heard of GDPR until today. A lovely lady from the government Software Advisory Service called me and tried to sell printers... And software and GPDR compliance and anything else she could thing of.

I did a quick google and frankly was a bit confused! Then got caught up in operational stuff...

Then this thread pops up!

We are almost entirely B2B, (we manufacture for trade customers and our own fitting aluminium windows and doors etc) the only B2C we do is over a small “trade counter” (that we are winding down) we do no marketing at all to private individuals and tbh would rather not do B2C. All our B2B marketing is very old school, sales reps calling into premises, we occasionally (every 12months or so) do mail shots but they are usually to old customers showcasing new products etc or from internet searches for business who might be interested in what we do.

We do sometimes (either given directly from our counter or from trade customers) have private individuals names and addresses, emails, phone numbers etc usually when we deliver direct to a house, it’s handy to have a contact in case the driver gets lost or what have you. Is this personal data?

We have a database driven SOP/CAM system that creates “orders” this “order” is created with ALL the information relating to it, so it stores the exact specification of what is to be manufactured (and communicates this to our in-house manufacturing process) it then schedules and produces delivery notes and eventually invoices. After the data is entered initially it is largely automatic, where a completed process will trigger the next critical action etc.

Once the order is completed it sits in the database for ever, it is never looked at again unless we have a warranty claim/ other issue or occasional BSI type audit.

Keeping the order details for ever is brilliant for our trade customers, it means they can call us after 10+ years and we can confirm specifications etc long after the contracts and purchase orders have gone.

I think the database has several million orders going back to the late 90s (obviously the program is not the same but still allows access to the data) the only way we could know if there is personal data in those orders is to look at each order!

Do I have to worry about the odd email or phone number being stored for a site delivery?

The other thing that kind of worries me is DDI and mobile numbers, as I recon 99% of my customers (and me) have DDI and mobiles in their email signatures, it is not uncommon for emails to end up in the factory or with drivers, it is often simpler to print the email than to try and re communicate it’s content.

Wilmslowboy

4,216 posts

207 months

Wednesday 25th October 2017
quotequote all
Yep ...I'm involved in this good old chestnut (together with a team of about 15 others in our business)...legal, marketing, tech, compliance, information security etc etc etc)

Large business
Mainly consumer
Huge amounts of data (personal consumer and employee) millions of records
At least a couple dozen different data stores
100+ customer data entry/ creation points
several dozen partner relationships, who data is exchanged with.


As we probably failed to fully meet the standards of existing pecr and DPA reqs we have a lot to do. I think our project cost will be close to or above the suggested business average I.e, "€1.3 million"

The "system" part of the project probably constitutes 25% of the overall project.




It is a real opportunity for us to challenge how much direct marketing we do going forward (and therefore how much personal data we collect, process and retain).




jonamv8

3,153 posts

167 months

Wednesday 25th October 2017
quotequote all
Frimley111R said:
jonamv8 said:
So how exactly are they enforcing this?! Are they going to visit premises and audit CRMs etc?
Clearly not. I suspect they will just come down on hard on anyone reporting a business for 'spamming' them. It'll be 'policing by fear'. All it takes is for one customer to report a business...
Ok so say somebody claims to have received a few emails and reports your organisation, what will happen? Warning? Investigation? If so what would investigation entail? What if the emails were personal BDM and not spam? I just cant see how its going to work for smaller organisations who develop business using email as one of their channels. Fair enough Vodafone woth 1m+ people on their list but the smaller players will be scared into trying to comply which will cost them money but with change comes opportunity for those in the business of supporting these firms who want to attempt at compliance.

Eric Mc

122,096 posts

266 months

Wednesday 25th October 2017
quotequote all
DELETED: Comment made by a member who's account has been deleted.
Great to hear.

anonymous-user

55 months

Wednesday 25th October 2017
quotequote all
Is there an exemption for the major credit file people?

Frimley111R

15,690 posts

235 months

Thursday 26th October 2017
quotequote all
Just one piece of info that might help people: GDPR covers any information you hold that can identify someone. If you're not sure just ask yourself this question.

Sheepshanks

32,828 posts

120 months

Thursday 26th October 2017
quotequote all
plasticpig said:
Many companies don't register with the ICO because processing and holding data for the purposes of payroll is exempt as is holding data for the marketing of their own goods and services and data held for accounting purposes.
I've never seen that scope of exemption under ICO - could you point to it? It would be great as it covers everything we do!


I notice now the ICO have said they're going to develop a way to continue to charge businesses for registering - although they haven't figured out what that's going to be yet. The requirement to register was supposed to go away under GDPR. Apparently only 10% of UK companies register anyway.

Met with French and German colleagues yesterday - they always love to point at laws and regulations and they're very excited about GDPR.

anonymous-user

55 months

Thursday 26th October 2017
quotequote all
DELETED: Comment made by a member who's account has been deleted.
It's interesting as one request for a car insurance quotation (as an exanple) can result in tens of records being created many of which will have a low level credit check involved.


plasticpig

12,932 posts

226 months

Thursday 26th October 2017
quotequote all
Sheepshanks said:
I've never seen that scope of exemption under ICO - could you point to it? It would be great as it covers everything we do!


I notice now the ICO have said they're going to develop a way to continue to charge businesses for registering - although they haven't figured out what that's going to be yet. The requirement to register was supposed to go away under GDPR. Apparently only 10% of UK companies register anyway.

Met with French and German colleagues yesterday - they always love to point at laws and regulations and they're very excited about GDPR.
https://ico.org.uk/for-organisations/guide-to-data-protection/exemptions/

ICO said:
Most organisations that process personal data must notify the ICO of certain details about that processing. However, the Act provides exemptions from notification for:

organisations that process personal data only for:
staff administration (including payroll);
advertising, marketing and public relations (in connection with their own business activity); and
accounts and records;
some not-for-profit organisations;
organisations that process personal data only for maintaining a public register;
organisations that do not process personal information on computer.

Eric Mc

122,096 posts

266 months

Thursday 26th October 2017
quotequote all
plasticpig said:
Sheepshanks said:
I've never seen that scope of exemption under ICO - could you point to it? It would be great as it covers everything we do!


I notice now the ICO have said they're going to develop a way to continue to charge businesses for registering - although they haven't figured out what that's going to be yet. The requirement to register was supposed to go away under GDPR. Apparently only 10% of UK companies register anyway.

Met with French and German colleagues yesterday - they always love to point at laws and regulations and they're very excited about GDPR.
https://ico.org.uk/for-organisations/guide-to-data-protection/exemptions/

ICO said:
Most organisations that process personal data must notify the ICO of certain details about that processing. However, the Act provides exemptions from notification for:

organisations that process personal data only for:
staff administration (including payroll);
advertising, marketing and public relations (in connection with their own business activity); and
accounts and records;
some not-for-profit organisations;
organisations that process personal data only for maintaining a public register;
organisations that do not process personal information on computer.
What's left that isn't exempted?

Sheepshanks

32,828 posts

120 months

Thursday 26th October 2017
quotequote all
DELETED: Comment made by a member who's account has been deleted.
Sure. But the need to register was supposed to go away under GDPR. The ICO have just said they will continue to charge people, but haven't quite figured it out yet.

https://iconewsblog.org.uk/2017/10/05/ico-fee-and-...

Eric Mc

122,096 posts

266 months

Thursday 26th October 2017
quotequote all
Eric Mc said:
What's left that isn't exempted?
DELETED: Comment made by a member who's account has been deleted.
Any chance you could precy it for me?

When someone asks a question I always try to answer rather than redirect them to a website.

Or is the list so long it's too tedious to list?

Sheepshanks

32,828 posts

120 months

Thursday 26th October 2017
quotequote all
Eric Mc said:
Or is the list so long it's too tedious to list?
I suppose it's 'everything else'.

Clearly, they want to encompass as much as they can. Even the definitions seem nonsense - "personal data" isn't someone's name but it becomes personal if there's pretty well any other reference to them (business or personal). But a business wouldn't keep a name and nothing else.

plasticpig

12,932 posts

226 months

Thursday 26th October 2017
quotequote all
Sheepshanks said:
I suppose it's 'everything else'.

Clearly, they want to encompass as much as they can. Even the definitions seem nonsense - "personal data" isn't someone's name but it becomes personal if there's pretty well any other reference to them (business or personal). But a business wouldn't keep a name and nothing else.
You wrong there IMO. My name identifies me as an individual because it's unique. There is no one with the same name in the rest of the world. Google my name and the only hits that come back relate to me. So just holding my name and nothing else in a database identifies me.

That's just my forename and surname BTW.






Eric Mc

122,096 posts

266 months

Thursday 26th October 2017
quotequote all
plasticpig said:
You wrong there IMO. My name identifies me as an individual because it's unique. There is no one with the same name in the rest of the world. Google my name and the only hits that come back relate to me. So just holding my name and nothing else in a database identifies me.

That's just my forename and surname BTW.
How is a holder of your name supposed to know that?

plasticpig

12,932 posts

226 months

Thursday 26th October 2017
quotequote all
Eric Mc said:
How is a holder of your name supposed to know that?
They don't need to know that. Companies need to take into consideration that a name alone can be a unique identifier for the purposes of GDPR.




Eric Mc

122,096 posts

266 months

Thursday 26th October 2017
quotequote all
plasticpig said:
Eric Mc said:
How is a holder of your name supposed to know that?
They don't need to know that. Companies need to take into consideration that a name alone can be a unique identifier for the purposes of GDPR.
"Can be" a unique identifier or "is" a unique identifier?

Isn't that the problem.

Eric Mc

122,096 posts

266 months

Thursday 26th October 2017
quotequote all
But how is the holder of a person's name supposed to decide whether that person's name is a "common or garden" name and therefore not a unique identifier.

Most names are not unique and therefore you would have to have lots of other data points about that person before you had to decide that their name alone was enough to identify them as one person and one person only. Even my name, which is not that common a combination, has shown around four to five similar names when a Google search is conducted. And every person in the world isn't identifiable by Google.

Eric Mc

122,096 posts

266 months

Thursday 26th October 2017
quotequote all
I'm just wondering what great benefit this set of regulations will bring.