UK OFFICE
West Nautical18A Osborne RoadJesmondNewcastle upon TyneNE2 2ADUnited Kingdom
Tel: +44 191 478 9920
CYPRUS OFFICE
Limassol Marina,Nireas Building,Office 3,3601 Limassol,Cyprus
Tel: +3 572 505 1423
MIDDLE EAST OFFICE
The Binary Tower By Omniyat,8th Floor,Office 808,32 Marasi Drive Street,Business Bay,Dubai,United Arab Emirates
Tel: +1 646 207 7545
Who we are
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Privacy Impact Assessments (PIA’s) are an integral part of taking a ‘privacy by design’ approach. PIA’s are a tool that West Nautical uses to identify and reduce the privacy risks of a project or service. A PIA can reduce the risk of harm to individuals through misuse of their personal information and helps West Nautical to design a more efficient and effective process for handling personal data.
The core principals of the PIA process are integrated within our existing project and risk management policies with the aim of reducing the resources necessary to conduct the assessment and spreading awareness of privacy throughout the Company.
An effective PIA will allow West Nautical to identify and fix problems at an early stage. PIAs must be applied to new projects or services as well as processes that involve changes to an existing project or service.
West Nautical has a process that outlines how we will approach PIAs.
PIA’s assist West Nautical in identifying privacy risk, which is the risk of harm through an intrusion into privacy. This is the risk of harm through use or misuse of personal information. Some ways that this risk can arise are through personal information being:
The outcome of a PIA is to minimise privacy risk. The aim of this policy is to enable West Nautical to develop an understanding of how it will approach the broad topics of privacy and privacy risk.
PIAs allow individuals to be reassured that we follow best practice when using their information. A project or service which has been subject to a PIA should be less privacy intrusive and therefore less likely to affect individuals in a negative way. A PIA should also improve transparency and make it easier for an individual to understand why their information is being used.The process of conducting the assessment will also improve how the Company uses information which impacts on individual privacy. This should in turn reduce the likelihood that the Company will fail to meet its legal obligations.
Conducting a PIA will help the Company build trust with our staff and the people using our services. The actions taken during and after the PIA process can improve the Company’s understanding of its stakeholders.
Consistent use of PIA’s will increase the awareness of privacy and data protection within the Company and ensure that all staff involved in designing projects think about privacy at the early stages.
When should we use PIAs?The core principals of PIA can be applied to any project that involves the use of personal data, or any other activity which could have an impact on the privacy of individuals.
A PIA should be used on new projects or services, or when making an amendment to a current project or service. The PIA should be built into the project management structure.
The Company will decide who is best placed to carry out a PIA. The Data Protection Officer (DPO) is well placed to have a significant role in a PIA. However, the PIA is designed to be used by anyone within the Company. For the PIA to be effective it should include some input from various people within the Company who are involved in a project or a service and who will each be able to identify different privacy risks and solutions.
The PIA should be flexible so that it can be integrated with the Company’s existing approach to managing projects. The PIA should incorporate the following:• Identify the need for a PIA.• Describe the information flows.• Identify the privacy and related risks.• Identify and evaluate the privacy solutions.• Sign off and record the PIA outcomes.• Integrate the outcomes into the project plan.• Consult with internal and external stakeholders as needed throughout the process.
Screening questions to assess if a PIA is required
If the answer is yes to any of the questions below, then using a PIA may be useful.
Identify the need for a PIA – Explain what the project aims to achieve, what the benefits will be to the organisation, to individuals and to other parties.
You may find it helpful to link to other relevant documents related to the project, for example a project proposal.
Also summarise why the need for a PIA was identified (this can draw on your answers to the screening questions).
Data Flow• How is the information collected?• How is the information stored?• How is the information used?• How is the information deleted?
Describe the information flows.
The collection, use and deletion of personal data should be described here, and it may also be useful to refer to a flow diagram or another way of explaining data flows. You should also say how many individuals are likely to be affected by the project or service.
Privacy Risks• Are there any privacy risks to individuals?• Are there any compliance risks to the Company, such as fines for non-compliance?• Are there any Company level risks?
Explain what practical steps you will take to ensure that you identify and address privacy risks. Who should be consulted, internally and externally? How will you carry out the consultation? You should link this to the relevant stages of your project management process.
Consultation can be used at any stage of the PIA process.
identify the privacy related risks.
Identify the key privacy risks and the associated compliance and corporate risks. Larger-scale PIAs might record this information on a more formal risk register.
Identify privacy solutions.
Describe the actions you could take to reduce the risks, and any future steps which would be necessary (e.g. the production of new guidance or future security testing for systems).
Sign off and record the PIA outcomes.
Who has approved the privacy risks involved in the project? What solutions need to be implemented?
Integrate the PIA outcomes back into the project plan.
Who is responsible for integrating the PIA outcomes back into the project plan and updating any project management paperwork? Who is responsible for implementing the solutions that have been approved? Who is the contact for any privacy concerns which may arise in the future?
We may update this policy from time to time so we suggest you review this page occasionally. If you have any questions or concerns regarding the policy or the way in which we use our data please email privacy@westnautical.com. This policy was last updated in May 2018.
In the event that something went wrong we would always try our best to resolve things. Please do speak to our Privacy Team first as we may be able to quickly and easily resolve the problem. In the event that you wish to make a complaint about how your personal data is being processed, or how your complaint has been handled, you have the right to lodge a complaint directly with the Information Commissioners’ Office who’s website is http://www.ico.org.uk/ or calling 0330 123 1113.
Please contact us if you have any questions about our privacy policy or the information we hold about you. You can email us using privacy@westnautical.com, write to us at Privacy Team, Baltic Place, South Shore Road, NE8 3AE or telephone on 0191 478 9920.
