DATA REGULATION
“Organisations must have clear rules on
The individual’s right to be forgotten, as applied to most services, is similar to the existing right to have data deleted. If an employee is leaving a company, for example, they may ask to be deleted from a TMC’s system. The TMC
retention and deletion of information – they cannot keep it forever”
is obliged to inform the indi- vidual what data it holds and then to delete it. In theory,
this is relatively simple, but it requires the TMC to
communicate the deletion to any parties to whom it has forwarded the data. The same information should also be removed from back-up systems and if one of these is overlooked, the TMC could inadvertently retain the information – to its cost. “The right to be forgotten only applies
to certain types of data under certain types of justification under the law,” says Kasey Chappelle, chief privacy officer at American Express Global Business Travel. “It applies to data that is being processed with consent for a particular transaction after that trans- action is complete and it doesn’t apply to data held under other justifications. It is not unqualified, so if it needs to be kept to fulfil
to a minimum, accurate, secure and retain it no longer than necessary. Any business with 250 staff or more, or
with fewer employees but which is engaged in high-risk activity or is a public authority, is legally obliged to appoint an internal or external data protection officer (DPO), who has to secure data, make sure supplier channels are secure, get confirmation from suppliers that they are compliant and, where appropriate, get proof. Travel buyers should ensure their TMC has the latest information about travelling employees – regularly updated employee data and/or HR feeds should aid this process. Organisations that have collected and
are processing customers’ personal data according to the law do not have to get reconfirmation of permission. If you rely on individuals’ consent to process their data – there are other lawful justifications (see box, right) – make sure it meets the GDPR standard on being “specific, granular, clear, prominent, opt-in, properly documented and easily withdrawn”, advises the Informa- tion Commissioner’s Office (ICO). In addition, if, for example, a company
asks a TMC what meal requests an employee makes when he or she travels, the TMC cannot give that information because it could reveal the religious and/or health status of the individual. “The TMC is legally obliged to have that conversation only with the traveller directly,” says Richard Bristow, director of Tamite Secure IT. “These days, in systems where customers are booking directly using a self-booking tool, it is not such an issue, but when conveying the same information in a telephone conversation, it does become an issue.”
BUYINGBUSINESSTRAVEL.COM BBT May/June 2018 79
GDPR cheat sheet
Samantha Simms, founder of the Information Collective, has these tips on last-minute preparations for GDPR
■ Create a data inventory that details the personal information you are holding and using, how and why, the security measures you have taken to protect it, to whom it is transferred and how long you will keep it ■ Determine the lawful basis or justification on which you are processing personal data, which comprises six options, including: consent, which requires a positive opt in; to fulfil a contract or give a quote prior to a contract; legal obligation, where you cannot fulfil said obligation without processing personal data; and vital interests, i.e. to protect someone’s life ■ Appoint a data protection officer, if appropriate ■ Companies must write and display prominently a privacy policy that explains how they propose to process data. A privacy policy should spell out the lawful basis for the processing of data. Provide links to the policy anywhere an individual may opt in to use of their data ■ Controllers must ensure processors acting on their behalf establish appropriate security measures ■ Define relationships in contracts with your suppliers, so that there is no doubt whatsoever about who is a controller and who is a processor and, therefore, who is responsible in the event of a data breach
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