The H. E. Butt Foundation (‘we’ or ‘us’ or ‘our’) is committed to ensuring the security and protection of the personal information that we process, and to providing a compliant and consistent approach to data protection. We aim to have a robust and effective data protection program in compliance with existing law and abiding by best practices in data protection. We also regularly update and expand our policies to meet the demands of GDPR and emerging U.S. data protection laws.
The H. E. Butt Foundation is dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective and fit for the purpose, and that demonstrates an understanding of and appreciation for changing regulations. Our preparation and objectives for data privacy are summarised in this statement and include the development and implementation of data protection roles, policies, procedures, controls, and measures to ensure maximum and ongoing compliance.
IN PLAIN ENGLISH: We gather data to serve our guests. We never sell data with outside entities.
HOW WE PROTECT YOUR DATA
The H. E. Butt Foundation already has a consistent level of data protection and security across our organization. Here are some of the ways we work to protect your data:
- Information Audits – we carried 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 – our data protection policies and procedures to meet the requirements and standards of GDPR and other relevant data protection laws, including:
- Data Protection – IT, Communications, and registrars 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 policies and retention 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 erasure procedures in place with our registrars to meet the new ‘Right to Erasure’ obligation for all non-required guest data, and we have IT and registrars to assist with such requests.
- Data Breaches – we have a communications plan 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 – we store information in the United States, and we have robust procedures and safeguarding measures in place to secure 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) – our registrars and communications department provide users with access to their personal information upon request, free of charge, within 30 days of the request. Our procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply to ensure that communications with data subjects are compliant, consistent and adequate.
- Legal Basis for Processing – Where applicable, we maintain records of our processing activities.
- Privacy Notice/Policy – our Privacy Notice(s) ensure 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 – our consent mechanisms for obtaining personal data ensure 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.
- Direct Marketing – the wording and processes for direct marketing include 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 procedures and assessment templates for carrying out impact assessments.
- Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting, etc), we have drafted agreements to ensure that they (as well as we), meet and understand their/our obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, and technical and organizational measures in place.
- Special Categories Data – special category data is only processed where necessary. Where we rely on consent for processing, this is explicit and is verified by a signature.
DATA SUBJECT RIGHTS
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide access to information via H.E. Butt Foundation staff. Individuals have the right to access any personal information that the H. E. Butt Foundation processes about them and to request that information:
- 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, 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 instances
INFORMATION SECURITY & TECHNICAL AND ORGANIZATIONAL MEASURES
H. E. Butt Foundation takes the privacy and security of individuals and their personal information very seriously and take measures and precautions 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 SSL, password policies, regular accounting audits, human resources, retention schedules, and a steering committee.
ROLES AND EMPLOYEES
The H. E. Butt Foundation has designated a Senior Director of IT and has appointed a technology steering committee to develop and implement our roadmap for complying with the new data protection regulation. The team is responsible for promoting awareness privacy policies across the organization, assessing our compliance with privacy law, identifying any gap areas, and implementing the new policies, procedures, and measures.
The H. E. Butt Foundation understands that continuous employee awareness and understanding is vital to the continued compliance of privacy laws. We have an employee training program for all employees and as part of our onboarding process for new employees.