Deluxe Cruises 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 recognised our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection legislation.
Deluxe Cruises 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.
Compliance with GDPR
Deluxe Cruises has a consistent level of data protection and security across our organisation aim to be fully compliant with the GDPR. This includes : –
o 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.
o 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.
o 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.
o International Data Transfers & Third-Party Disclosures – where Deluxe Cruises 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. 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.
o 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.
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 in our office of an individual’s right to access any personal information that Deluxe Cruises processes about them and to request information about: –
Information Security & Technical and Organisational Measures
Deluxe Cruises 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 unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: access controls, password protection, sophisticated internet security and anti virus and malware software.
GDPR Roles and Employees
Deluxe Cruises has designated Lesley Monk as our Data Protection Officer. The DPO is responsible for promoting awareness of the GDPR across the organisation, identifying any gap areas and implementing the new policies, procedures and measures.
Deluxe Cruises understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR.
If you have any questions about our compliance with GDPR, please contact Lesley Monk. firstname.lastname@example.org +44 1202 767926
Deluxe Cruises is the trading name of Deluxe Cruises Limited registered in England under company number 06027735