Compliance Statement


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.


JCE Contracting 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 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.

JCE Contracting Ltd 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

Contracting Ltd already 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 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/implementing new data protection
policies and procedures to meet the requirements and standards of the GDPR and
any relevant data protection laws, including: -

o 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 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 – 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

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 –JCE
Contracting Ltd does not store or transfer
personal information outside the EU, if we did, we would have robust procedures
and safeguarding measures in place to secure, encrypt and maintain the
integrity of the data. Our procedures would include a continual review of the
countries with sufficient adequacy decisions, as well as provisions for binding
corporate rules; standard data protection clauses or approved codes of conduct
for those countries without. We would 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

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 adequate.

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 have revised 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.

Obtaining Consent - we have revised 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 do not carry out direct marketing, however
if we did, we would 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 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 have
developed stringent procedures and assessment templates for carrying out impact
assessments that comply fully with the GDPR Article 35 requirements. We 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 (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.

Special Categories
- where we obtain and process any special category
information, we do so in complete compliance with the Article 9 requirements
and have high-level encryptions and 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 is explicit
and is verified by a signature, with the right to modify or remove consent
being clearly signposted.

Data Subject

In addition to the policies and procedures
mentioned above that ensure individuals can enforce their data protection
rights, we provide easy to access information in our office of an individual’s
right to access any personal information that JCE Contracting Ltd processes
about them and to request information about: -

What personal data we
hold about them

The purposes of the

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

Security & Technical and Organisational Measures

JCE Contracting
Ltd 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,
including: - Access control, Password protection, Documents access
control via restricted access etc.

GDPR Roles
and Employees

Contracting Ltd have designated Jerry Cullen as our Appointed Person 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.

Contracting Ltd 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 specific to the 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 about our
preparation for the GDPR, please contact Jerry

Cullen on 01373455690Type text here