Hotel Owner April 2018 | Page 22

ADVICE ADVICE PREPARING FOR GDPR Advice Are you ready for GDPR? New EU rules on how you can use your customers’ personal data - General Data Protection Regulation - are coming into effect next month. If you’re not already up to speed, we did a whip-round the experts for some last minute advice on how to fall into line ROYTHORNES SOLICITORS core principles of data protection remain but By Julia Seary, company commercial with tighter controls. partner, Rothornes Solicitors There are many old and new rules coming into force but the crucial aspects How ready are you for GDPR? to bear in mind for any industry include the General Data Protection Regulation, or GDPR tighter scope of explicit consent (do you for short, is the topic on everyone’s mind have it and, if not, how do you legally get it), at the moment but what does it actually increased transparency (the new ‘right to be mean and how ready are businesses? A forgotten’ and ‘right to be informed’ rules) recent survey revealed that only 7% felt very and the need to demonstrate compliance if prepared for the GDPR regulations. Instead the Information Commissioner’s Office (ICO) the majority felt somewhat ready (50%) with suspect any misconduct. 25% feeling not very or not at all prepared ARMADILLO CRM and 4% having no awareness of GDPR at all. have Nicholas Blake is the head of data different ‘pain points’ with the new regulation and digital operations at Armadillo but a good place to start is with an action CRM, which specialises in customer plan such as this: relationship marketing Each business 1.  N ominate a and GDPR industry lead or Data Processing Officer (DPO) to front the initiative 2. C  arry out a data mapping review to understand what data you hold and where it has come from 3.  Update your customer facing privacy notices 4. R  eview and update all relevant data- related policies and procedures 5. C  larify and document the legal basis that you are relying on for processing data 6.  Remove any opt-out pre-ticked consent boxes and replace with opt-in boxes 7.  Check your marketing lists comply with the new regulation 8. U  nderstand how and when to respond to 22 www.hotelowner.co.uk Despite GDPR changing the methods of Data Subject Access Requests (DSARs) capturing and managing customer data for 9.  Check your IT systems can properly good, the regulations don’t need to herald support compliance 10.  Review all third-party the end of useful data. There are still ways supplier in which businesses can continue to gather arrangements with regard to the new useful data and, crucially, help gain customer regulatory requirements trust at the same time. Here are the three 11.  Review any international data flow if relevant to your company 12. Ensure staff are adequately briefed and carry out ongoing audits essential areas to address. 1. Justify the data you are collecting Once GDPR is in force you can only collect data for specific, explicit and legitimate The key take home message is that you must purposes. Every company should be able to have a lawful basis to process individuals’ answer the question: “Why are we collecting data. Whether it be in regard to marketing this data, and is it justified?” bulletins, IT security, customer relationships, Transactional data is easier to answer employee data storage or data transfer, the – retailers have a legitimate reason to April 2018