GDPR Compliance Statement

Introduction

The EU General Data Protection Regulation (“GDPR”) came into force across the European Union on May 25, 2018 bringing significant changes to data protection law.

GDPR aims to standardize data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.

Our Commitment

Talon Storage Solutions, Inc. (“Talon”) (‘we’ or ‘us’ or ‘our’) is 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 applicable national laws. Talon is dedicated to safeguarding the personal information under our remit and in developing an effective and compliant data protection regime program. Our 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 GDPR

Talon has a consistent level of data protection and security across our organization. However, in connection with GDPR we have taken the following steps:

  • Internal Information Audit—carrying out a company-wide internal 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—reviewing our audit results against our current data protection policies and procedures to confirm compliance with the requirements and standards of GDPR and other applicable data protection laws, including:
    • Data Protection—our policy and procedures covering data protection has been confirmed 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—our retention policy has been confirmed to meet the ‘data minimisation’ and ‘storage limitation’ principles and any personal information, if ever received, will be stored, archived and destroyed compliantly and ethically. We have erasure procedures in place to meet the new ‘Right to Erasure’ obligation.
    • 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 have been disseminated to all employees.
    • Subject Access Request (SAR)—we have SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge.
  • Legal Basis for Processing—we have reviewed processing activities and 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 Policy—we have revised our Privacy Policy 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.
  • Data Protection Impact Assessments (DPIA)—we have taken steps to assure that we will not process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data.
  • Processor Agreements—where we use any third-party to process personal information on our behalf, we have drafted compliant processor agreements.
  • Special Categories Data—we have taken steps to assure that we do not process any special category information.

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 of an individual’s right to access any personal information that Talon 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

Talon 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.