As more and more SMEs begin to realise the importance of getting a head-start on GDPR compliance, we’ve been out and about helping them understand where changes need to be made in their personal data processing.
Of course, every company is different – no two organisations handle data in identical ways and processes differ considerably from sector to sector. The steps to achieving compliance for a marketing agency will vary from those required by a legal firm, for example.
However, through delivering GDPR workshops tailored to a large number of different businesses we’ve noticed a few common regulation-breaching activities that are frequently being overlooked. And when we’ve flagged these up, they’ve all been met with the same response: “I didn’t think about that!”
So, to help ensure you do think about them and don’t fall victim to the same accidental oversights, here are our top five GDPR minefields you might have overlooked:
- Visitor books
Often located in the reception and within easy access of the main door to the office, the visitor book is packed full of personal data such as full names, contact details and vehicle registration numbers. In busy offices with lots of people coming and going, it’s easier than you might think for records like these to go ‘missing’. And depending on how frequently you host guests and how quickly your book fills up, you could be holding data for months, during which time it could easily become inaccurate and out of date – directly breaking one of the 6 data processing principles.
- Shared passwords
We all know the advice: don’t use the same password for multiple accounts because if one gets hacked, it’s likely that they all will be. Admittedly, it is easier to have one all-encompassing combination – particularly within a business – but it can be a risky move, especially if it’s written down somewhere. One of the rules of the GDPR is that adequate protection of personal data is in place and can be proven, so an updated password policy should definitely be on your compliance checklist.
- Job applications
Once a vacancy has been filled in a business, the focus turns to ensuring the new recruit is settling in and getting to grips with their role. But what happens to all the CVs from unsuccessful applicants that you had pouring into your inbox? Personal data can only be held for the duration it’s needed under the GDPR, so – unless you have an individual’s consent that you can retain their details for future positions – you need to be careful not to store it for longer than necessary.
- Little black books
(The business kind, of course!) Many companies have a ‘little black book’ of sorts, where the most secretive data – such as credit card details and bank numbers – is recorded for easy access to those who need it frequently. And while such a practice might seem like a harmless timesaver, what if that record fell into the wrong hands? Taking note of the data you store in this way and carefully assessing the safeguarding measures you have in place is crucial.
- Marketing lists
It’s more than likely that your marketing database is going to need some kind of GDPR-proofing before 25 May 2018 arrives. The way that you obtain consent for a potential customer to be added to your email list, for example, will probably need to be altered as the new rules require an explicit ‘opt in’ from the individual – no more sneaky check-boxes allowed! Along with ensuring you have permission for personal data to be stored, keeping your distribution lists up-to-date and accurate is similarly crucial – forget to remove unsubscribers at your peril…
These are just a few things you might need to take a closer look at in your own business, but this list by no means covers the extent of what you need to consider. No matter how far along you are in your journey to compliance, failing to cover standard data processing practices like these could result in a letter/call/email from the Information Commissioner’s Office that you really don’t want to receive!
To find out more about how to get your personal data processes in tip-top, GDPR-compliant shape, just give us a shout!