GDPR Compliance Statement

Our Commitment

The AP Partnership 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 data protection principles. We recognise our obligations in meeting the demands of the GDPR and the UK’s Data Protection Act 2018.

The AP Partnership are dedicated to safeguarding the personal information under our remit and in maintaining a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the GDPR. Our objectives for GDPR compliance have been summarised in this statement and include the development and implementation of data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

Why do we need personal information about you?

The AP Partnership needs certain personal information, which is knowingly disclosed to us by you, to enable us to;

  • Respond to your request for services
  • Give you access to our client portal

We will endeavour to keep any personal information we hold both accurate and up to date.

Separate Compliance statements are available for employees and customers and can be obtained by contacting our Head Office, details at the end of this statement.

When you visit our website, or utilise any of the services that we provide, we also automatically collect certain information about your usage of the website and/or other services provided through the use of server-side logging or tracking cookies.

This information is collected to enable us to:

  • monitor site/service activity for the purposes of preventing malicious activity
  • collect aggregated information for the purposes of improving our services offered

Our website makes use of cookies. A cookie is a small text file sent to your computer by our servers. Information within this cookie is passed back and forth to the website as you navigate the site. Cookies allow us to monitor website usage or to personalise the website experience to you. Your browser can be configured to reject cookies, information on doing so can be found at https://www.aboutcookies.org/, however doing so, may have a negative impact on the usage of our sites and or systems.

How we satisfy the GDPR requirements

The AP Partnership has a consistent level of data protection and security across our organisation, to that end we regularly undertake the following actions:

  • 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 & Proceduresimplementing and reviewing 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 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 –our retention policy and schedule 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 ‘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 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.
    • International Data Transfers & Third-Party Disclosures – The AP Partnership will not store or transfer personal information outside the EU. We will never sell, distribute or lease your personal information to any other party unless we have consent to do so, or unless required to do so by law or if it is necessary to fulfil contractual obligations to you.
    • Subject Access Request (SAR) – we have SAR procedures to accommodate the 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 have reviewed 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 Act are met.
  • Privacy Notice/Policy – we have Privacy Notices 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 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 have 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 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’s 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, 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 Datawhere 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 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 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, in the office, during induction etc.of an individual’s right to access any personal information that The AP Partnership 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 Organisational Measures

The AP Partnership 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. 

All data is stored on servers running a minimum of AES-128 encryption (via BitLocker) encryption and on the cloud.

GDPR Roles and Employees

The AP Partnership 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 compliance in implementing the new policies, procedures and measures.

The AP Partnership 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.

If you have any questions please contact Dr Adam Wickes BSc, LLM, PhD, MCIPD.  Tel: 01733 217690.  

Contact us to schedule your complimentary consultation.