GDPR / policy

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 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

US Dedicated LLC ("we", "us" or "our") is committed to ensuring the security and protection of the personal information that we process, and to providing 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. We recognise our obligations in updating and expanding this program to meet the demands of the GDPR.

US Dedicated LLC is dedicated to safeguarding the personal information under our remit and to developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for, the regulation. Our preparation and objectives for GDPR compliance are 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

US Dedicated LLC already has a consistent level of data protection and security across the organization; our aim is to be fully compliant with the GDPR. Our preparation includes:

• Information audit. 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 and procedures. 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 and 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 right to erasure and are aware of when this and other data subjects' rights apply, along with any exemptions, response time frames 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 and third-party disclosures. Where US Dedicated LLC 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 sufficient 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 requests. We have revised our procedures to accommodate the 30-day timeframe for providing the requested information and for making this provision free of charge. Our 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 and policy

We have revised our privacy notices 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.

Direct marketing

We have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions, a clear notice and method for opting out, and unsubscribe features on all subsequent marketing materials.

Data protection impact assessments

Where we process personal information that is considered high risk, involves large-scale processing or includes special category or 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.

Processor agreements

Where we use any third party to process personal information on our behalf (payroll, recruitment, hosting and so on), we have drafted compliant processor agreements and due diligence procedures for ensuring that they, as well as we, meet and understand their and 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 of 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 encryption and protections on all such data. Special category data is only processed where necessary and only 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 above, we provide easy-to-access information on an individual's right to access any personal information that US Dedicated LLC processes about them and to request information about:

• 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 or will be disclosed
• How long we intend to store their personal data
• 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 and technical and organisational measures

US Dedicated LLC takes the privacy and security of individuals and their personal information very seriously and takes 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 SSL, access controls, password policy, encryption, pseudonymisation, restriction, authentication and IT practices.

Changes to our GDPR policy

If we decide to change our GDPR policy, we will post those changes on this page.

Contacting us

If there are any questions regarding this GDPR policy you may contact us using the information below.

US Dedicated LLC
900 N Alameda St. #200
Los Angeles, CA 90012
United States
[email protected]

Last revised 11.12.2018