OUR GDRP POLICY

The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union and the European Economic Area. It also addresses the export of personal data outside the EU and EEA. It came into enforce on the 25th May 2018. 
1. DATA PROTECTION PRINCIPLES
SKM Group Limited is committed to processing data in accordance with its responsibilities under the GDPR .
GDPR requires that personal data shall be :
a. Processed lawfully, fairly and in a transparent manner in relation to individuals;
b. Collected for specified, explicit and legitimate purposes, not further processed in a manner that is incompatible with those purposes for archiving purposes.
c. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
d. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are being processed, are erased or rectified without delay;
e. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for no longer periods insofar as the persona data will be processed solely for archiving purposes for legislative purposes.
f. All data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
2. GENERAL PROVISIONS
a. This policy applies to all personal data processed by the company.
b. The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.
d. The personal data processed under this provision will comprise of no more than the following fields. Full name, address, postcode, phone number, email address, additional information. The field “additional information “ will include any information that has been offered by the customer for help in delivering the product or any information they require to go alongside their order.
3. LAWFUL, FAIR & TRANSPARENT PROCESSING
a. To ensure its processing of data is lawful, fair and transparent, the company shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to the company shall be dealt with in a timely manner.
4. LAWFUL PURPOSE
 a. All data processed by the company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public tasks or legitimate interests.
b. Each party shall ensure that it processes the personal data fairly and lawfully in accordance with the Privacy and Data Legislation during the term of the agreement. Further, the Data Controller shall ensure the processes satisfies an appropriate condition under the schedule in the table below (under point 9).
5. DATA ACCURACY
The Data Processor agrees to ensure that the Personal Data processed on the order is accurate to their knowledge and agrees to review the accuracy if required. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
6. DATA SUBJECT RIGHTS
Data subjects have the rights in relation to their personal data under the Privacy and Data Legislation. Those rights include:  
 i. The rights to be informed
ii. The rights to access
iii. The right to rectification  
iv. The right to erasure 
v. The right to restrict processing 
vi. The right to data portability
vii. The right to object
viii. The right in relation to automated decision make and profiling all data To facilitate the above rights, the Data Processor agrees to store or record the personal data processed under the Agreement in a structured, commonly used and machine -readable that is compliant with current Privacy and Data Legislation.
7. ARCHIVING / REMOVAL; 
a. To ensure that personal data is kept no longer than necessary, the company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy shall consider what data should/ must be retained, for how long and why.
8. SECURITY
a. The company shall ensure that personal data is stored securely, using modern software that is kept up to date.
b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information. 
c. When personal data is deleted this should be done safely such that the data is irrecoverable. 
d. Appropriate back-up disaster recovery solutions shall be in place.
9. BREACH
 In the event of a breach of security leading to the accidental or the unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data the Company shall promptly assess the risks and if appropriate report this breach to the ICO. 
Outlined below is the services and purposes the Personal data will undergo and the specific Personal Data that will be used by each of those services/purposes. The description should clearly identify the various stages at which the Personal Data will pass between the Data Processor and the Data Controller.
Service & Purpose : To process an order and ship the product(s) to the data controllers customer
Personal Data : Customer full name, address, phone number and any additional information
Date Communication : Email & phone
Service & Purpose : To share the order data with a third-party courier, in line with the third-party access agreement 
Personal Data : Customer full name, address, phone number and any additional information
Date Communication : To be decided by the data processor 
Service & Purpose : To undertake any warranties, repairs or replacements
Personal Data : Customer full name, address, phone number and any additional information
Date Communication : Email & phone
QUESTIONS
If you have any queries or questions about the way we handle your data in line with the GDPR, then please feel free to contact us.