GDPR Compliance Statement

Editor's note: This post was originally written in May 2018. Since 31 January 2020, the provisions of the EU GDPR have been incorporated directly into UK law as the UK GDPR, which sits alongside an amended version of the Data Protection Act 2018. The key principles, rights and obligations remain the same. If you have any questions about our compliance, please contact us.

The EU General Data Protection Regulation (“GDPR”) came into force on 25 May 2018.

The Regulation aims to standardise data protection laws and processing across the EU, giving people greater rights to access and control their personal information.

As Visufund is a company based in the United Kingdom, we are required by law to comply with the GDPR. This statement describes our commitment to do this and explains the steps we have taken to ensure compliance.

Our Commitment

At Visufund, we are committed to ensuring protection of all personal information that we hold, and to provide and protect all such data. We recognise our obligations to remain compliant, and regularly review and update our policies to meet the requirements of GDPR.

Visufund is dedicated to safeguarding the personal information under its control and in maintaining a system that meets its obligations under the regulations.

How We Prepared for GDPR

Visufund has always had a consistent level of data protection and security across the organisation, and we have introduced new measures to ensure GDPR compliance.

Information Audit

Prior to the GDPR law coming into force, we carried out an audit of information previously held and ensured that it was compliant with the new regulations.

Policies and Procedures

We have revised 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 document for data protection has been revised to meet the standards and requirements of the GDPR. Accountability measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities, with a dedicated focus on privacy and the rights of individuals.
• Data Retention and Erasure: We have reviewed and updated our retention policy to ensure that we meet the 'data minimisation' and 'storage limitation' principles, and that personal information is stored, archived and destroyed in accordance with our obligations. We have procedures in place to meet the new 'Right to Erasure' obligation.
• Data Breaches: Our procedures ensure that we have safeguards in place to identify, assess, investigate and report any personal data breach as early as possible. Our procedures have been explained to all employees.
• Subject Access Request (SAR): We have revised our SAR procedures to accommodate the revised one month timescale for providing the requested information and for making this provision free of charge.

Privacy Policy

We have revised our Privacy Policy to ensure it complies 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 reviewed 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.

Email Subscriptions

We understand that the GDPR does not replace the PECR (Privacy and Electronic Communications (EC Directive) Regulations 2003). We are fully committed to complying with PECR regulations, and we have always ensured that we obtain consent before sending any electronic marketing to personal addresses. As part of our information audit, we reviewed the wording and processes for direct e-marketing, including clear opt-in mechanisms for marketing subscriptions and providing unsubscribe features on all subsequent marketing materials.

Third parties

Where we use any third-party to process personal information on our behalf, we have due diligence procedures for ensuring that they meet and understand their GDPR obligations.

Data Subject Rights

We provide easy-to-access information via our website of an individual’s right to access any personal information that Visufund 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 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 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 may use
• the right to lodge a complaint and who to contact in such instances

Information Security

Visufund takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure 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.

GDPR Roles and Employees

Visufund understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and we have involved all employees in our preparation plans.