Privacy Info
USJETi
United States Jarvis Export Trading International Incorporated
Complies Foremost United States of America Internet and Privacy
practices
& GDPR
Compliance Statement
& Cookie
Information
Introduction
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 21st Century brings with its 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.
Our
Commitment
(www.USJETi.com) United States Jarvis Export Trading International Inc. (‘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 and
the [UK’s Data Protection Bill/ relevant United States of America DP law].
(www.USJETi.com) United States Jarvis Export Trading International Inc. 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 Prepare for the
GDPR
(www.USJETi.com) United States Jarvis Export Trading International Inc. already have a consistent level of data protection and security across our organization, 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 - [revising/implementing new] 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 (www.USJETi.com) United States Jarvis
Export Trading International Inc 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 enough 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.
- Legal Basis for
Processing - we are reviewing 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 are revising 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/are revising] 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/are revising] 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 organizational 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 [our website, in the office, during induction etc.] of an individual’s right to access any personal information that
(www.USJETi.com) United States Jarvis Export Trading International Inc. processes about them and to request information about: -
- What personal data
we hold about them ( The Form on web site )
- The purposes of the
processing ( person or company to contact us )
- The categories of
personal data concerned ( Limited to the web site form)
- The recipients to
whom the personal data has/will be disclosed ( all company employees and agencies we are involved with )
- How long we intend
to store your personal data for ( the Laws of United States of America determines )
- The right to have
incomplete or inaccurate data about them corrected or completed and the process for requesting this is okay
- 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 by request by form
- The right to lodge
a complaint or seek judicial remedy and who to contact in such instances
Information Security &
Technical and Organizational Measures
(www.USJETi.com) United States Jarvis Export Trading International Inc. 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: such as SSL, access controls, password policy, encryptions,
GDPR Roles and
Employees
www.USJETi.com) United States Jarvis Export Trading International Inc. have designated
Mr. Jarvis as our [Data Protection Officer (DPO)/Appointed Person] 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.
(www.USJETi.com ) United States Jarvis Export Trading International Inc.
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 will be provided to all employees prior to May 25th, 2018, and forms
part of our induction and annual training program.
COOKIES
Cookies are small text files that websites send to your
computer. A cookie can be thought of as an Internet user's identification card. They let the website know when the user has returned.
Cookies make the interaction between users and websites
faster and easier. Without cookies, it would be very difficult for a website to allow a visitor to fill up a shopping basket or to remember the user's preferences or registration details for a future
visit.
Cookies are not computer programs, and can't read other
information saved on your hard drive. They cannot be used to disseminate viruses, or get a user's email address etc. They only contain and transfer to the website as much information as the users
themselves have disclosed to that website. It is possible to opt out of cookies via your browser’s cookie settings.
For further information about managing and disabling
cookies on your computer see www.allaboutcookies.org/manage-cookies.
When you visit our sites, cookies are either served
directly by us, or by our business partners. Here is a description of the different kind of cookies we use.
Performance cookies They allow us to get to know how you
use our website. They are used to analyse visitor information such as usage, visitor numbers and help us see how effective our advertising is and to understand what you like. We also use this
information to help improve our website, make our marketing more relevant and improve the user experience.
Functionality cookies They allow us to provide additional
functionalities to the website, and will retain some settings information. Whilst not essential for the functionality of our site, they do enable extra features that should improve your
experience.
all cookie data is anonymised and stored
temporarily.
Cookies id
LIST OF
COOKIEs
COMPANY
DETAILS
CLASSIFICATION
PURPOSE
Google Performance Google cookies allow
us to use Google Analytics to measure web performance
Cdn. initial – web site .com is a cookie from our 1and1 .com hosting company for the internal form we use on our web site.
Microsoft cookie to offer translation of our web site to visitors.
Face book cookie to offer likes to other Facebook users