As of July 26, 2023
1. Introduction
This procedure document supplements the data subject access request (DSAR) provisions set out in the Walker Information, Inc. (hereinafter referred to as the “Company”) Privacy Policy and provides the process for individuals to use when making an access request, along with the protocols followed by the Company when such a request is received.
As a company, we need to collect personal information to effectively carry out our everyday business functions and services, and in some circumstances, to comply with the requirements of the law and/or regulations. Since we process personal information regarding individuals (data subjects), we are obligated under the General Data Protection Regulation (GDPR) to protect such information, and to obtain, use, process, store and destroy it, only in compliance with the GDPR and its principles.
1.1 The General Data Protection Regulation
The General Data Protection Regulation (GDPR) gives individuals the right to know what information is held about them, to access this information and to exercise other rights, including the rectification of inaccurate data. The GDPR is a standardized regulatory framework which ensures that personal information is obtained, handled and disposed of properly.
We are obligated under the GDPR and UK data protection laws to abide by the principles of the regulation, which ensure that personal information shall be:
- processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’)
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’)
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’)
- 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 processed, are erased or rectified without delay (‘accuracy’)
- 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 (‘storage limitation’)
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (‘integrity and confidentiality’)
The GDPR regulation also requires that “the controller shall be responsible for, and be able to demonstrate, compliance with the GDPR principles” (‘accountability’). The Company has adequate and effective measures, controls and procedures in place, which protect and secure your personal information and guarantee that it is only ever obtained, processed and disclosed in accordance with the relevant data protection laws and regulations.
2. What is Personal Information
Information protected under the GDPR is known as “personal data” and is defined as:
“Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
3. The Right of Access
Under Article 15 of the GDPR, an individual has the right to obtain from the controller, confirmation as to whether or not personal data concerning them is being processed. We are committed to upholding the rights of individuals and have dedicated processes in place for providing access to personal information.
Where requested, we will provide the following information:
- The purposes of the processing
- The categories of personal data concerned
- The recipient(s) or categories of recipient(s) to whom the personal data have been or will be disclosed
- If the data has been transferred to a third country or international organization(s) (and if applicable, the appropriate safeguards used)
- The envisaged period for which the personal data will be stored (or the criteria used to determine that period)
- Where the personal data was not collected directly from the individual, any available information as to its source
3.1 How to Make a Data Subject Access Request (DSAR)?
A data subject access request (DSAR) is a request for access to the personal information that the Company holds about you, which we are required to provide under the GDPR (unless an exemption applies).
You can make this request in writing using the details provided in section 7 below. Where a request is received by electronic means, we will provide the requested information in a commonly used electronic form (unless otherwise requested by the data subject).
3.2 What We Do When We Receive a Request
Identity Verification
Data Subject Access Requests (DSAR) are passed to the Privacy Officer as soon as received and a record of the request is noted. The person in charge will use all reasonable measures to verify the identity of the individual making the access request, especially where the request is made using online services.
We will utilize the request information to ensure that we can verify your identity and where we are unable to do so, we may contact you for further information, or ask you to provide evidence of your identity prior to actioning any request. This is to protect your information and rights.
If a third party, relative or representative is requesting the information on your behalf, we will verify their authority to act for you and again, may contact you to confirm their identity and gain your authorization prior to actioning any request.
Information Gathering
If you have provided enough information in your DSAR to collate the personal information held about you, we will gather all forms (hard-copy, electronic, etc.) and ensure that the information required is provided in an acceptable format. If we do not have enough information to locate your records, we may contact you for further details. This will be done as soon as possible and within the timeframes set out below.
Information Provision
Once we have collated all the personal information held about you, we will send this to you in a commonly used electronic form (or in writing if requested). The information will be in a concise, transparent, intelligible and easily accessible format, using clear and plain language.
4. Fees and Timeframes
DSARs are usually completed within thirty (30) days and are provided free of charge. We will provide the information in a commonly used electronic format, unless an alternative format is requested.
Whilst we provide the information requested without a fee, further copies requested by the individual may incur a charge to cover our administrative costs.
We will always aim to provide the requested information at the earliest convenience, but at a maximum, thirty (30) days from the date the request is received. However, where the retrieval or provision of information is particularly complex or is subject to a valid delay, the period may be extended by an additional sixty (60) days. If this is the case, we will write to you within thirty (30) days and keep you informed of the delay and provide the reasons.
5. Your Other Rights
Under the GDPR, you have the right to request rectification of any inaccurate data held by us. Where we are notified of inaccurate data, and agree that the data is incorrect, we will amend the details immediately as directed by you.
We will rectify the errors within thirty (30) days and inform you in writing of the correction and where applicable, provide the details of any third-party to whom the data has been disclosed.
In certain circumstances, you may also have the right to request from the Company, the erasure of personal data or to restrict the processing of personal data where it concerns your personal information, as well as the right to object to such processing. You can use the contact details in section 7 to make such requests.
6. Exemptions and Refusals
The GDPR contains certain exemptions from the provision of personal information. If one or more of these exemptions applies to your subject access request or where the Company does not act upon the request, we shall inform you at the earliest convenience, or at the latest, within thirty (30) days of receipt of the request.
7. Submission & Lodging a Complaint
To submit your data subject access request, please contact us at privacy@walkerinfo.com
