GDPR COMPLIANCE STATEMENT

INTRODUCTION

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. 

OUR COMMITMENT

PM+M Solutions for Business LLP, PM+M Wealth Management Ltd, PM+M Corporate Finance Ltd, PM+M (Holdings) Ltd and PM+M Ltd (‘PM+M’ or ‘we’ or ‘us’ or ‘our’) 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 law and abides by the 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.

PM+M are dedicated to safeguarding the personal information under our remit and 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.

DISCLAIMER

By using this website, users agree to accept the application of English law to govern matters between PM+M and themselves. Please read the following sections in our Disclaimer as they will explain what liabilities have been excluded by PM+M, and advise as to the accuracy and content of the website.

HOW WE ARE PREPARING FOR GDPR

PM+Malready have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR by 25th May 2018. Our preparation includes:

INFORMATION AUDIT

Carrying out a company-wide 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 AND PROCEDURES

Revising and implementing data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:

Data Protection – our main policy and procedure document for data protection is being overhauled to meet the standards and requirements of the GDPR. 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 – we are updating 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 will 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 will 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 will be robust and communicated to all employees, making them aware of the reporting lines and steps to follow.
International Data Transfers & Third-Party Disclosures – It is PM+M’s normal policy to keep our data within the EU, however if we are required to store or transfer personal information outside the EU, we will have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data.
Subject Access Request (SAR) – we will revise 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 will 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.

LEGAL BASIS 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 their information.has established relationships with reputable business partners that allow visitors to our website to link directly to sites operated by these partners.  Some of these sites may be “co-branded” with a PM+M logo; however, these sites are not operated or maintained by PM+M and PM+M is not responsible for their content or how any information is collected and processed.  It is therefore recommended that you review the privacy policy of the businesses that maintain these sites.  These sites may collect personal information from you that is then shared with PM+M.  The content of this policy will apply to information obtained in this manner.

Links to the websites operated by other third parties may also be provided for your convenience. Again, PM+M cannot be responsible for the content of these sites or how data is collected or processed and it is recommended that you review the privacy policy of the applicable third-party website.

OBTAINING CONSENT

For circumstances where we will require consent we will have 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.

DIRECT MARKETING

We are revising the wording and processes for direct marketing, and where appropriate this will include a clear opt-in for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.

DATA PROTECTION IMPACT ASSESSMENTS (DPIA)

Where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we will have  procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We will have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).

PROCESSOR AGREEMENTS

Where we use any third-party to process personal information on our behalf, we are in the process of agreeing 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.

SPECIAL CATEGORIES DATA

Where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have appropriate protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this will be explicit and will be verified by a signature, with the right to modify or remove consent being clearly signposted.

DATA SUBJECT RIGHTS

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we will provide easy to access information via our website, in the office, in PM+M’s Team Handbook and during induction, of an individual’s right to access any personal information that we 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 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 AND TECHNICAL AND ORGANISATIONAL MEASURES

PM+M takes the privacy and security of individuals and their personal information very seriously and we 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:

IT anti-virus security and malware protection, Secure Sockets Layer (SSL), access controls, password and authentication policy, encryptions, pseudonymisation, team/departmental restrictions, and in addition we will encourage use of our secure client portal.

GDPR ROLES AND EMPLOYEES

PM+M have designated Richard Hesketh as the Appointed Person for PM+M Wealth Management Ltd and Jane Parry as the Appointed Person for all other PM+M entities. PM+M 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.

PM+M 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 will deliver employee training sessions which will be provided to all employees prior to May 25th 2018, and will form part of our induction and annual training program.

If you have any questions about our preparation for the GDPR, please contact Sharon Pye, Compliance Manager, sharon.pye@pmm.co.uk


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PM+M Limited Registered in England, Company Registration Number: 03661915
PM+M Solutions For Business LLP Registered in England, Registered Number: OC311588
PM+M Corporate Finance Limited, Registered in England, Company Number: 03661920
PM+M Wealth Management Limited, Registered in England, Company Number: 03626554.

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