I have read the Information Commissioner’s Office guidelines for compliance with the new General Data Protection Regulation (GDPR) rules. This document that follows explains how I comply. If you have given me your email address (by emailing me or subscribing to my website, for example) you should read this to reassure yourself that I am looking after your data extremely responsibly.
If any of you understand this better than me and believe there’s something else I should be doing, do let me know. I value the security of your information extremely highly and will never intentionally breach the rules. However, the rules are designed for organisations and most authors are sole traders, ie just work on our own, and do our best to keep up.
The 12 points below are my response the the ICO booklet, “Preparing for the General Data Protection Regulation – 12 Steps to Take Now.” Here we go!
- Awareness
I am a sole trader so there is no one else in my organisation to make aware.
- The information I hold:
- Email addresses of people who have emailed me and to whom I have replied – automatically saved in gmail.
- Email addresses, names and self-identified descriptors (eg “parent”, “school librarian”) of people who have signed up to my mailing list via the opt-in link on my website – held in Mailchimp
I do not share this information with anyone. Ever.
- Communicating privacy information
- I have put this document on my website, with a link from my sign-up section for new subscribers.
- I will be contacting everyone on my Mailchimp database via a mailshot, alerting them to this document. I will remind them of what they signed up to, and remind them that they can unsubscribe at any time and their data will be deleted.
- Individuals’ rights
On request, I will delete data.
If someone asked to see their data, I would take a screenshot of their entry/entries.
If they unsubscribe themselves from the Mailchimp list, their data is automatically deleted.
- Subject access requests
I aim to respond to all requests within a week.
- Lawful basis for processing data
- If people have emailed me, they have given me their email address. I do not actively add it to a list but gmail will save it. I will not add it to any database or spreadsheet.
- If people have opted into my Mailchimp list (by subscribing to my website) they have actively opted in, in the knowledge that they will receive occasional Newsletters about forthcoming books or mine, plus competitions.
- Consent
Once I’ve contacted everyone with a reminder about the T&C of my holding their data, I regard this consent as confirmed for a year, or until the person asks me to remove the data. I have never harvested email addresses, nor would I. Anyone on my lists has contacted me.
Consent is not indefinite, so I will make sure that I remind subscribers that they can unsubscribe or ask for their data to be removed.
- Children
Young people sometimes email me but I don’t know their age unless they tell me – and I only have their word for that. I would not deliberately keep their email address (but gmail would save it in my account.) Since I am not “processing” their data, I am not required to ask for parental consent. I reply to the email and don’t contact them again.
- Data breaches
I have done everything I can to prevent this, by strongly password-protecting my computer, Mailchimp, Google and social media accounts, such as Instagram, Facebook and Twitter. If any of those organisations were compromised I would take steps to follow their advice immediately.
- Data Protection by Design and Data Protection Impact Assessments
I have familiarised myself with the ICO’s code of practice on Privacy Impact Assessments as well as the latest guidance from the Article 29 Working Party, and believe that I am using best practice.
- Data Protection Officers
I have appointed myself as the Data protection Officer, in the absence of anyone else!
- International
My lead data protection supervisory authority is the UK’s ICO.