Coronavirus GDPR FAQ

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Some frequently asked questions about how GDPR and compliance is impacted by the Coronavirus Pandemic

Yes, absolutely.

We’re happy for you to contact us for free to ask for specific input on contingency plans and GDPR implications of Coronavirus.

We can also help you with your DPIA risk assessments or other “hands-on” help – this is exactly what we do. You can find out more about our GDPR support services here or contact us if you’d like to know more.

If your employees aren’t used to working from home or remotely, then you will need to ensure you carry out a risk assessment (a DPIA in GDPR terms) to consider the implications of them doing so. 

So, as well as considering the practicalities of them doing so, you will need to consider the technological and human implications of remote access to personal data.

We’ve got a free checklist of things to consider whilst carrying out your contingency planning, that should help.

Ideally yes, particularly if it is unusual for employees to work remotely and/or you have no internal process for doing so.

Our contingency planning blog may help with the kind of risks you need to consider.

The key thing is to make sure they fully understand the implications from a GDPR perspective of now working from, accessing systems remotely as well as the security risks (others having access to devices, systems, etc.)

A lot of the risks you need to consider are covered in our contingency blog but we’ve also produced a checklist posteryou can use for your employees to remind them of their obligations. You can download that here.

Simply put, no.

All organisations are expected to do what they can to apply usual GDPR compliance measures, including meeting timescales for dealing with subject access, and other individuals’ rights. However, the ICO have indicated that whilst they will not be allowing extended timescales in dealing with GDPR obligations, they accept that whilst organisations adapt to alternative ways of working and attentions are elsewhere, there will be some flexibility.

Essentially, this means you should try and do what you can, be clear on what is achievable and what is not (to any requestors) and document your approach and reasons why you may have problems exercising rights (e.g. because paper files are back at the office, or systems are not accessible remotely). That way if they were to report you to the ICO, the ICO would probably tell them to cut you some slack under the circumstances.

The ICO have published a Coronavirus Hub, although it’s limited. Simply put, GDPR compliance continues regardless of the Coronavirus, so things should be (as much as possible), business as usual.

You’ll find the ICO’s current guidance here

In a general sense, yes. There has been quite a lot of media speculation about its security and just what Zoom has access to.

That said, if you take a practical approach, carry out a DPIA to identify the risks and tell attendees so they know how you will use Zoom, you should be OK. There’s more on this in our video conferencing blog post.

The ICO have published their approach to enforcement during the Coronavirus. You can read about it in our blog post.

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