Our Data Protection Unit has created a four-tier approach to ensuring a satisfactory data protection compliance procedure by the client:
1. Identification: Initial compliance including audit by the firm held in conjunction and direct relationship with the client. This provides the firm with an initial snap-shot of the situation within the client’s environment. The initial audit to be carried out by the firm will focus mainly on data held in electronic format and processed automatically however focus will also be given for data stored/processed manually since this will also require compliance at a future date.
2. Awareness Raising: The firm and the client may at any stage agree to devising customized awareness raising sessions amongst internal representatives of the client.
3. Ongoing Identification and Fine Tuning: The firm provides ongoing advice, necessary legal drafting of any policies, forms and website content as well as notification and reporting of any new legislation in this field which may have an impact on the client.
4. Services of a Personal Data Representative: The firm at this stage will act as intermediary between Data Protection Commissioners Office (DPC) and the Client, as well as any sectoral regulator where applicable. The role of the firm will be that of providing support and clarification as well as advocate on behalf of the client with the DPC.
The firm will also indicate to the DPC the daily realities of work carried out by client and the way in which this must be taken into consideration by the DPC when issuing regulations of direct interest to the client. The firm intends to acquire accreditation from DPC once this is offered so as to ensure a more comprehensive accredited service for the client. The firm will also provide assistance via written submissions to the DPC on behalf of the client with regards to special legislation and subsidiary regulations addressed to the sector in which the client operates specifically.
The Overriding Policy of our DPU
While we will not hesitate to advise on any radical changes to be effected to bring the client in conformity, our DPUs emphasis is on making those minimal changes absolutely necessary to bring the client in line with current legislation so as to ensure that the clients core operations continue uninterruptedly.