General Data Protection
Regulation (GDPR)
[Name] • [Date]
1 General Data Protection Regulation (GDPR)
Learning Objectives
What is personal data?
What are the consequences?
Data protection principles and rights
Our company’s data protection policy
2 General Data Protection Regulation (GDPR)
What’s has changed?
Data Protection Act
General Data
Protection Regulation
(GDPR)
3 General Data Protection Regulation (GDPR)
What is personal data?
• “... information relating to a living individual who can be
identified from that data...”
• “…it may include expressions of opinion…”
• “…held in manual or electronic systems…”
• ICO guidance
4 General Data Protection Regulation (GDPR)
What constitutes personal
data?
Our company’s Your medical
Your salary details
annual report information
NO YES YES
Your anonymous Your photo or
Your name and
response to a survey image on a CCTV
date of birth
YES question NO camera YES
5 General Data Protection Regulation (GDPR)
What is personal data under
GDPR?
“...IP addresses...”
“…automated personal data and data held in manual systems…”
“…key-coded (pseudonymised) personal data…”
Sensitive personal data Special categories of
personal data (Article 9)
6 General Data Protection Regulation (GDPR)
Special categories of personal data
Your name and date Racial or ethnic
Genetic data
of birth origin
NO YES YES
Data concerning
Religious or political
sex life or sexual Biometric data
beliefs
YES orientation YES YES
7 General Data Protection Regulation (GDPR)
Lawful processing
1. Explicit consent of the data subject
2. Necessary for the performance of a contract
3. Necessary for legal or judicial reasons
4. Necessary to protect the data subject’s
best interests
5. Necessary to perform a task carried out in
the public interest
6. Necessary for legitimate interests
8 General Data Protection Regulation (GDPR)
What rights do data subjects have?
I don’t want to I want to be able to Did I agree to that? I
receive your take my data and didn’t see a privacy notice
marketing letters reuse it on other on your website when I
and promotions platforms typed in my details
Does the right to I want to have I want to find out what
be forgotten any errors data you have about me
apply to me? corrected and how you’re using it
Please stop using my data until you’ve
checked there is a legitimate purpose
9 General Data Protection Regulation (GDPR)
Rights of
individuals under
GDPR:
1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure (“right to be forgotten”)
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights on automated decision making & profiling
10 General Data Protection Regulation (GDPR)
When it goes wrong
Shop owner fined
TalkTalk fined 1b customer
for using instore
£400k by ICO for accounts hacked,
CCTV without
cyber attack admits Yahoo
registering
Social worker Insurance firm
Loan company
drives off with fined £150k for
fined £70k for
family court data on losing 60,000
spam texts
roof customers’ data
11 General Data Protection Regulation (GDPR)
You make the
call: Is it a
breach?
“She asked me to remove her information from our
systems – but it’s required for regulatory reasons so I
refused”
Breach
No Breach
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You make the
call: Is it a
breach?
“At first, he gave us his consent to use his data but then he
changed his mind – I told him that it wasn’t allowed”
Breach
No Breach
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You make the
call: Is it a
breach?
“We assumed she gave us her consent because she
placed an order with us and friended us on social media”
Breach
No Breach
14 General Data Protection Regulation (GDPR)
Data breach notifications
A data breach only occurs No. It can occur if data is accessed
when data is lost inappropriately due to a lack of internal controls
Breaches are only serious No. Unauthorised access, disclosures, loss,
if data is actually taken destruction, and alteration are also serious
Look at Yahoo – isn’t it No. Under GDPR, you just have 72 hours
best to keep quiet? to notify of data breaches
15 General Data Protection Regulation (GDPR)
Fines under GDPR
• Infringements of rights, basic principles and rules on
international transfers:
4% of worldwide turnover or €20 million
• Failure to notify of data breaches:
2% of worldwide turnover or €10 million
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Scenario 1
What do you think?
a) Great – it looks like Jayne is on top of GDPR already
b) Not bad – but Jayne can get consent verbally from
customers too
c) Poor – Jayne must ensure that consent is active
There’s a pre-checked
d) Poor – consent is only required for children under 13
box when customers
years
place their order. It
gives us consent for
future marketing.
17 General Data Protection Regulation (GDPR)
Scenario 2
What do you think?
a) Excellent – it looks like Peter really knows his stuff
b) Great – there are no restrictions on transfers outside the EU
c) Not bad – but Peter must ensure there are adequate
We’ve got a US firm safeguards for EU data
helping us process d) Poor – Peter must get consent from the supervisory authority
customer data. It’s all first
big-data analytics
wizardry.
18 General Data Protection Regulation (GDPR)
Our Data Protection Policy
1. What personal data we use and how
2. Our rules and procedures – creating, storing, sharing and disposing of personal data
safely
3. Identifying our Data Protection Officer and how to contact them
4. Requiring everyone to read and implement our Data Protection Policy
19 General Data Protection Regulation (GDPR)
Do
Read our Company's Data Protection Policy – make sure you understand the rules
and why they're important
Follow our policies and rules whenever you use personal data – taking particular
care to prevent unauthorised access, loss, theft or alteration
Speak out promptly if you accidentally lose, delete or transfer personal data to
someone else – our firm has just 72 hours to report it
Talk to your manager or our Data Protection Officer if you have any questions or
concerns
20 General Data Protection Regulation (GDPR)
Don’t
x Keep using customers’ personal data for marketing if they ask you to stop
x Transfer personal data outside the EU without ensuring there are
adequate protections in place
x Leave personal data lying around on a desk or unattended onscreen
x Collect or use children’s personal data without getting parental consent
first
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Any Questions?
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Next steps
Call _______ on _______ if you need information or
guidance
Call _______ on _______ if you need to raise concerns
Access self-study courses on our e-learning portal for further
training [or optionally – Complete your mandatory training on
our corporate e-learning portal]
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