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The EU General Data Protection Regulation (“GDPR”) comes 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 21 st 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 standardise

data protection laws and processing across the EU; affording individuals stronger, more consistent

rights to access and control their personal information.


Our Commitment


DeLever Limited (‘we’ or ‘us’ or ‘our’) are 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 recognise our

obligations in updating and expanding this program to meet the demands of the GDPR.


DeLever Limited are 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


DeLever Limited already have a consistent level of data protection and security across our

organisation, however it is our aim to be fully compliant with the GDPR by 25th May 2018. Our

preparation includes: -

  • 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 new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:



























  • 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 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 and who the information is disclosed to.

  • Obtaining Consent - we 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) – DeLever Limited do not process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data. 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, we have updated our 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 – DeLever Limited do process any special category information.


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 our website of an individual’s right to access any personal information that DeLever Limited 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 and who to contact in such instances


Information Security & Technical and Organisational Measures


DeLever Limited takes the privacy and security of individuals and their personal information very seriously and takes every reasonable measure and precaution to protect and secure the personal data that we process. We have information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: -


Access controls, password policy, encryptions of hard drives and portable drives and flashdisks, Anti-virus and firewall protection, Phishing email recognition training and awareness for all employees, GDPR awareness training for employees and 3 rd party processors, GDPR policies and procedures to help staff keep the rights of the data subject to mind at all times, Policies and

procedures and agreements for 3rd party processors to ensure they comply with the GDPR when acting on our behalf.


GDPR Roles and Employees


DeLever Limited has designated Katherine Byfield as our Data Protection Officer (DPO) and has 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 organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new

policies, procedures and measures.


DeLever Limited understands that continuous employee awareness and understanding is vital to the continued compliance with the GDPR and has involved our employees in our preparation plans. We have implemented an employee training program specific to the GDPR which will be provided to all employees prior to May 25 th , 2018, and forms part of our induction and annual training program.


If you have any questions, please contact Katherine Byfield ([email protected]).

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DeLever 'General Data Protection Regulations' (GDPR) Policy


please read...

Personal Data

DeLever GDPR Compliance Statement

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Our Commitment to  Your SECURITY!

  • 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 focuson 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 minimisation’ 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 DeLever Limited stores or transfers personal information outside the EU, we have robust procedure and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. 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.