Full GDPR Compliance Statement

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 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 EU; affording individuals stronger, more consistent rights to access and control their personal information.

Our Commitment

Charanga is 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.

Charanga 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 are Preparing for the GDPR

Charanga already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR by 25th May 2018.

Our preparation includes: –

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 of an individual’s right to access any personal information that Charanga processes about them and to request information about: –

Information Security & Technical and Organisational Measures

Charanga 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 unauthorised access, alteration, disclosure or destruction and have several layers of security measures.

Charanga hosts its websites on Amazon Web Service’s (AWS) European datacentres in Ireland. The Charanga servers in AWS are in a locked-down VPC (virtual private cloud), where access to those machines in the VPC is logically isolated from any other AWS instances.

Charanga uses AWS’ geographic controls to ensure that no data leaves the EU datacentres in Ireland. This ensures we are in compliance with Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

The VPC acts like an isolated LAN. Network access is strictly controlled by security groups. Traffic in and out of the VPC from specific machines (i.e the webserver and only the webserver) to the wider internet is further limited by firewall rules which only permit a limited set of protocols; HTTP, HTTPS, SMTP and SSH.

SSH access into the VPC is only allowed from a set of whitelisted IP addresses. Password access is not permitted, nor is root access. Access is solely from SSH keypairs, which are reviewed on a regular basis.

Data is stored on an AWS RDS (Relational Database Service) instance, which is a managed MySQL database. Backups are automatically maintained and securely stored on Amazon’s S3 infrastructure. The AWS VPC, RDS and S3 services all comply with ISO27001.

GDPR Roles and Employees

Charanga have designated Paul Fletcher as our Data Protection Officer  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 organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.

If you have any questions about our preparation for the GDPR, please contact Paul Fletcher, Data Protection Officer (DPO) on gdpr@charanga.com

Awards and recognition for the Charanga music education programmes and digital learning resources

© 2018 Charanga Ltd, all rights reserved   |   Cookie & Privacy Policy