Skin & Tonic Mobile Health & Beauty 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 a robust and effective data protection program in place which complies with existing law and abides by the data protection principles.
Skin & Tonic Mobile Health & Beauty 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 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.
Skin & Tonic Mobile Health & Beauty have a consistent level of data protection and security across our organization, and are fully compliant with the GDPR which includes:
· Information Audit – Consistent audit of our information 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 – Ensuring our data protection policies and procedures are meeting the requirements and standards of the GDPR and any relevant data protection laws, including: -
o 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.
o Data Retention & Erasure – Our retention policy and schedule meet the ‘data minimization’ and ‘storage limitation’ principles and personal information is stored, archived and destroyed compliantly and ethically. We have erasure procedures in place to meet the ‘Right to Erasure’ obligation.
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.
· Privacy Notice/Policy- our Privacy Notice 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 their information.
· Obtaining Consent – when obtaining personal data, we ensure 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.
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 Skin & Tonic Mobile Health & Beauty 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 use
· The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Information Security & Technical and Organizational Measures
Skin & Tonic Mobile Health & Beauty 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 unauthorized access, alteration, disclosure or destruction.
GDPR Roles and Employees
Skin & Tonic Mobile Health & Beauty have designated Rachael Warren and Jessica Murray as our Appointed Persons to implement our roadmap for complying with the new data protection Regulation. These persons are responsible for promoting awareness of the GDPR across the organization, assessing our GDPR readiness, identifying any gap areas and implementing any new policies, procedures and measures.
If you have any questions about our GDPR policies, please contact Rachael Warren or Jessica Murray.