The EU General Data Protection Regulation (“GDPR”) comes into force across the
European Union on 25th May 2018 and brings 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 new
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.
Flowbird Group UK (Incorporating Parkeon LTD & Cale Access UK LTD) are
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. We have
always had a robust and effective data protection program in place which complies with
existing laws and abides by data protection principles. However, we recognise our
obligations in updating and expanding this program to meet the demands of the GDPR and
the UK’s Data Protection Bill 2017.
Flowbird Group UK 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.
How we are preparing for the GDPR
Flowbird Group UK already has a consistent level of data protection and security across
our organisation, however it is our aim to be fully compliant with the GDPR across the
Group. Our preparation includes: –
• Information Audit – carrying out a company-wide information audit to identify and
assess what personal information we hold, where it comes from, how and why it is
processed and if and to whom it is disclosed.
• Policies & Procedures – revising data protection policies and procedures to meet
the requirements and standards of the GDPR and all relevant data protection laws,
2 Issue 4
Data Protection – our main policy and procedure document for data protection has been
overhauled to meet the standards and requirements of the GDPR. Accountability and
governance measures are in place to ensure that we understand, evidence our obligations
and responsibilities and adequately disseminate to all our staff and partners; with a
dedicated focus on privacy by design and the rights of individuals.
o Data Retention & Erasure – we have updated our retention policy and
schedule to 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.
o 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 employees, making them aware of the reporting
lines and steps to follow.
o International Data Transfers & Third-Party Disclosures – where
Flowbird Group UK stores or transfers personal information to Third-Parties
or outside the EU, we have robust procedures and safeguarding measures in
place to secure, encrypt and maintain the integrity of the data. We carry out
strict due diligence checks with all recipients of personal data to assess and
verify that they have appropriate safeguards in place to protect the
information, ensure enforceable data subject rights and have effective legal
remedies for data subjects where applicable.
o Subject Access Request (SAR) – we have revised our SAR procedures to
accommodate the revised 30-day timeframe for providing the requested
information and for making this provision free of charge. Our new 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
• Legal Basis for Processing – we are reviewing all processing activities to identify
the legal basis for processing and ensuring that each basis is appropriate for the
activity it relates to. Where applicable, we also maintain records of our processing
activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1
of the Data Protection Bill are met.
• Privacy Notice/Policy – we are revising our Privacy Notice(s) to comply with the
GDPR, ensuring that all individuals whose personal information we process have
been informed of why we need it, how it is used, what their rights are, who the
information is disclosed to and what safeguarding measures are in place to protect
3 Issue 4
• Obtaining Consent – we are revising our consent mechanisms for obtaining
personal data, ensuring that individuals understand what they are providing, why
and how we use it and giving clear, defined ways to consent to us processing their
information. We have developed stringent processes for recording consent, making
sure that we can evidence an affirmative opt-in, along with time and date records;
and an easy to see and access way to withdraw consent at any time.
• Direct Marketing – we have revised the wording and processes for direct
marketing, including clear opt-in mechanisms for marketing subscriptions; a clear
notice and method for opting out and providing unsubscribe features on all
subsequent marketing materials.
• Processor Agreements – where we use any third-party to process personal
information on our behalf (i.e. Payroll, Recruitment, Hosting etc.), we have drafted
compliant Processor Agreements and due diligence procedures for ensuring that they
(as well as we), meet and understand their/our GDPR obligations. These measures
include initial and ongoing reviews of the service provided, the necessity of the
processing activity, the technical and organisational measures in place and
compliance with the GDPR.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can
enforce their data protection rights, we provide access to information on request of an
individual’s right to access any personal information that Flowbird Group UK processes 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
• The right to lodge a complaint or seek judicial remedy and who to contact in such
Information Security & Technical and Organisational Measures
Flowbird Group UK 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.
4 Issue 4
GDPR Roles and Employees
Flowbird Group have designated Mr Luc Porchon as the group Data Protection Officer
(DPO) and have appointed a data privacy team to develop and implement our roadmap for
complying with the new data protection Regulation. The team are 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.
Flowbird Group UK has appointed a Data Protection Lead. Flowbird Group UK understands
that continuous employee awareness and understanding is vital to the continued compliance
of the GDPR and have involved our employees in our preparation plans. We have
implemented an employee training program which will be provided to all employees prior to
May 25th, 2018, and forms part of our induction and annual training program.
If you have any questions or comments regarding our preparation for the GDPR please
contact us by email at firstname.lastname@example.org or in writing at this address
Flowbird Group UK, Discovery Court, 551-553 Wallisdown Road, Bournemouth BH12 5AG.