Our statement

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Introduction
The UK General Data Protection Regulation (“GDPR”) became effective on the 1st January 2021. The law covers the key principles along with rights and obligations when processing personal data in the United Kingdom and sits alongside the Data Protection Act 2018. It applies to any organisation who offers goods and services to individuals in the UK and/or monitors behaviour of any individuals in the UK. 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 it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the UK; affording individuals stronger, more consistent rights to access and control their personal information..
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Our Commitment
Key 2 Care Limited T/A Derbyshire Care Services 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 Data Protection Act 2018.
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We 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
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How We Have Prepared for the GDPR
We already have a consistent level of data protection and security across our organisation, with
emphasis on being compliant with the GDPR and Data Protection Act 2018. Our preparation includes: -
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• 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.
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• Policies & Procedures - data protection policies and procedures to meet the requirements and
standards of the GDPR and any relevant data protection laws, including: -
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o 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.
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o Data Retention & Erasure – we have updated our retention policy and 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 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.
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o 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.
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o International Data Transfers & Third-Party Disclosures – We do not store or transfer
personal information outside the UK. We ensure all recipients of personal data have
appropriate safeguards in place to protect the information. We have robust procedures
and safeguarding measures in place to secure, encrypt and maintain the integrity of the
data, ensure enforceable data subject rights and have effective legal remedies for data
subjects where applicable.
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o 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 GDPR and Schedule 1 of the Data Protection Act 2018 are met.
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• Privacy Notice/Policy – our Privacy Notice(s) 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.
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• Obtaining Consent - we have revised 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.
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• 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 will ensure stringent procedures and assessment templates for carrying out
impact assessments that comply fully with the GDPR’s requirements. We wil implement
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).
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• 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 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 organisational measures in place and
compliance with the GDPR.
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• Special Categories Data - where we obtain and process any special category information, we do
so in complete compliance with the GDPR 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 basis or the Data Protection Act 2018
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.
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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 we processes about them
and to request information about: -
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• 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 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
• The right to lodge a complaint or seek judicial remedy and who to contact in such instances

Information Security & Technical and Organisational Measures
We take 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
unauthorised access, alteration, disclosure or destruction and have several layers of security measures,
including: -
SSL Encryption, Access Controls, Password Policy , Vendor best practices, Content Restriction and MFA
(multi-factor authentication)

GDPR Roles and Employees
Key 2 Care Limited T/A Derbyshire Care Services have designated a Data Protection Officer (DPO) who is
responsible for the preparation and implementation of the new data protection Regulation.
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We understand that continuous employee awareness and understanding is vital to the continued
compliance of the GDPR and have involved our employees in our preparation and implementation plans.
We have implemented GDPR into our employee training program highlighting specifics of the data
protection regulations and law and have ongoing training with existing employees, as well as session
with new starters, temporary staff and those returning from absences.

If you have any questions about our preparation for the GDPR, please contact:
DATA PROTECTION OFFICER
KEY 2 CARE LTD T/A DERBYSHIRE CARE SERVICES
UNIT 1 DERWENT PARK
214-216 LONDON ROAD
DERBY
DE1 2SX
(01332) 275060

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