GDPR Compliance Statement
The EU General Data Protection Regulation (“GDPR”) came into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.
The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardize data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
McKinley Quality Management LLC (‘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 recognize our obligations in updating and expanding this program to meet the demands of the GDPR and the consumer privacy laws within the United States.
McKinley Quality Management LLC is dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and 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 the GDPR
McKinley Quality Management LLC already has a consistent level of data protection and security across our organization, however we have been GDPR compliant since July 1st, 2018. Our preparation included:
- Information Audit – carrying out a company-wide 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 – implementing data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
- Data Protection – our main policy and procedure document for data protection has been overhauled 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 – we have updated our retention policy and schedule to ensure that we meet the ‘data minimization’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
- 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 are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
- International Data Transfers & Third-Party Disclosures – where McKinley Quality Management LLC stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
- Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
- Legal Basis for Processing – we have reviewed all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also 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 Notice/Policy – we have revised our Privacy Notice(s) 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.
- Obtaining Consent – we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
- Direct Marketing – we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
- Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
- Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.
- Special Categories Data – where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.
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 online request submission of an individual’s right to access any personal information that McKinley Quality Management LLC 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 instance.
Information Security & Technical and Organizational Measures
McKinley Quality Management LLC 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 unauthorized access, alteration, disclosure or destruction and have several layers of security measures, including: – enterprise level security, Validated SSL certificates across all McKinley Quality Management LLC network sites, encrypted, secure third-party CDN backup storage, password encryption and access policies, and more. Details available upon written request.
GDPR Roles and Employees
McKinley Quality Management LLC have designated Eugene Oliver as our Data Protection Liaison
and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team are responsible for promoting awareness of the GDPR across the organization, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
McKinley Quality Management LLC understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the which has been provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.
If you have any questions about our preparation for the GDPR, please contact Kristi Oliver at +1-530-KRIS or firstname.lastname@example.org.
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This privacy notice applies to all sites in the McKinley Quality Management LLC network, including but not limited to www.KristiOliver.com and all websites or properties within our network. All updates to this policy are amended at the bottom of this page, with time-date reference for your convenience.
Information Collection, Use, and Sharing
McKinley Quality Management LLC is the sole owners of the information collected on this site. We only have access to/collect information that you voluntarily give us via email or other direct contact from you. We will not sell or rent this information to anyone.
We will use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request, e.g. to ship an order.
Your Access to and Control Over Information
You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address or phone number given on our website…
- See what data we have about you, if any.
- Change/correct any data we have about you.
- Have us delete any data we have about you.
- Express any concern you have about our use of your data.
We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline.
Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the web page.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.
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Without limiting the generality of the foregoing, you may not:
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Please contact Eugene Oliver if you have any questions or concerns regarding these terms: +1-205-530-KRIS or email@example.com.
Third Party Terms and Copyrights
These guidelines are for McKinley Quality Management LLC licensees, authorized resellers, developers, customers, and other parties wishing to use Kristi Oliver, The Unveiling of Your Likeness™, The Framework™, and all other trademarks, service marks or images in promotional, advertising, instructional, or reference materials, or on their web sites, products, labels, or packaging.
Use of the McKinley Quality Management LLC logo, copyrighted materials (et al.) for commercial purposes without the prior written consent of McKinley Quality Management LLC or authorized agent, may constitute trademark infringement and unfair competition in violation of federal and state laws.
Use of McKinley Quality Management LLC trademarks may be prohibited, unless expressly authorized.
McKinley Quality Management LLCs’ trademarks, service marks, trade names, and trade dress are valuable assets.
In following these guidelines, you help us protect our valuable trademark rights and strengthen our corporate and brand identities.
By using a McKinley Quality Management LLCs’ trademark, in whole or in part, you are acknowledging that McKinley Quality Management LLC is the sole owner of the trademark. The goodwill derived from using any part of a McKinley Quality Management LLC trademark exclusively inures to the benefit of and belongs to Kristi Oliver. Except for the limited right to use as expressly permitted under these Guidelines, no other rights of any kind are granted hereunder, by implication or otherwise.
Authorized Use of McKinley Quality Management LLC Trademarks
- Advertising, Promotional, and Sales Materials: Only McKinley Quality Management LLC and its authorized resellers and licensees may use the McKinley Quality Management LLCs’ Logo or name in advertising, promotional, and sales materials excluding advertising through the Google, Google Adwords, Facebook, Facebook Advertising platforms.
Regarding Google, Google Adwords, Facebook and Facebook Advertising platforms–all uses of McKinley Quality Management LLCs’ trademarks, graphic symbols, logos, and icons must be granted express, written permission. Before use, all requests for permission should be submitted to firstname.lastname@example.org
Unauthorized Use of McKinley Quality Management LLCs’ Trademarks
- Company, Product, or Service Name: You may not use or register, in whole or in part, McKinley Quality Management LLCs’ trademark, including McKinley Quality Management LLC-owned graphic symbols, logos, icons, or an alteration thereof, as or as part of a company name, trade name, product name, or service name except as specifically granted by express written permission.
- McKinley Quality Management LLCs’ Logo and McKinley Quality Management LLC-owned Graphic Symbols: You may not use the McKinley Quality Management LLCs’ Logo or any other McKinley Quality Management LLC-owned graphic symbol, logo, or icon on or in connection with web sites, products, packaging, manuals, promotional/advertising materials, or for any other purpose except pursuant to an express written trademark license from McKinley Quality Management LLCs’.
- Variations, Takeoffs or Abbreviations: You may not use any variation of the McKinley Quality Management LLCs’ logo for any purpose. Third parties cannot use a variation, phonetic equivalent, foreign language equivalent, takeoff, or abbreviation of a McKinley Quality Management LLCs’ trademark for any purpose.
- Disparaging Manner: You may not use a McKinley Quality Management LLCs’ trademark or any other McKinley Quality Management LLC-owned graphic symbol, logo, or icon in a disparaging manner.
- Endorsement or Sponsorship: You may not use any McKinley Quality Management LLCs’ trademark, including McKinley Quality Management LLC-owned graphic symbols/logos, or icons, in a manner that would imply McKinley Quality Management LLCs’ affiliation with or endorsement, sponsorship, or support of a third party product or service.
- McKinley Quality Management LLCs’ Trade Dress: You may not imitate the distinctive McKinley Quality Management LLC packaging, web site design, logos, or typefaces.
- Slogans and Taglines: You may not use or imitate a McKinley Quality Management LLCs’ slogan or tagline.
- Domain Names: You may not use an identical or virtually identical McKinley Quality Management LLCs’ trademark as a second level domain name.
Depictions of McKinley Quality Management LLCs’ Products
- Endorsement or Sponsorship: McKinley Quality Management LLC does not support the use of its logos, company names, product names, or images of McKinley Quality Management LLC products by other parties in marketing, promotional or advertising materials as their use may create the perception that McKinley Quality Management LLC endorses or sponsors the product, service or promotion.