GDPR Compliance

Langdon Customs and Excise Solutions Ltd – Commitment to GDPR

Langdon’s Commitment to GDPR

We are committed to providing our software solutions to our Clients in compliance with applicable laws and regulations in general and data privacy laws such as the EU General Data Protection Regulation (GDPR) in particular. We seek to partner with our Clients to help them understand how we achieve data privacy compliance as a processor and how the Langdon platform enables our Clients to achieve data privacy compliance as controller.

GDPR and what it means for you

Whenever the Data Protection Directive or the GDPR applies to our Clients, they are deemed the controller of the personal data included on the Langdon Platform and Langdon is deemed the processor. As such, both Langdon and our Client have to comply with their respective obligations under the Data Protection Directive and the GDPR accordingly. One side of these obligations relates to the controller-processor relationship, while the other side relates to the controller obligations vis-à-vis the data subject, typically the user of the Langdon Platform (i.e. employees, contractors and partners of our Clients).

We expect our Clients and their users to comply with all applicable laws and regulations in connection with the use of the Langdon Platform, in particular, making sure that our Clients have all rights and consents necessary to allow Langdon to use and process such data.

As a service provider, Langdon is committed to supporting our Clients in their compliance activities, including as outlined in GDPR Chapter Ill (Rights of the data subject), most notably the rights of access and rectification (Art. 15 + 16 GDPR), right to erasure or ‘right to be forgotten’ (Art.17 GDPR), right to data portability (Art. 20 GDPR), and right not to be subject to automated decision-making, including profiling (Art. 22 GDPR).

Our top 5 priorities for GDPR compliance

*(The following section refers to the Gartner Blog “Smarter with Gartner” on GDPR.) Gartner lists the top 5 priorities for organisations to focus on to ensure compliance when GDPR comes into effect. Below we explain Langdon’s position relating to these priorities:

#1 Determine your role under the GDPR

As a software solutions provider, Langdon is processing data on behalf of its Clients using the Langdon Platform; therefore Langdon is seen as a data processor under the GDPR. In light of existing data privacy laws and data security measures generally expected from a global cloud service provider such as Langdon, we have already implemented an information security program consisting of policies and procedures to help ensure that Langdon is acting in accordance with current and new compliance requirements when providing our services.

#2 Appoint a Data Protection Officer

The GDPR will require some organisations to designate a Data Protection Officer (DPO). Organisations requiring DPOs include public authorities, organisations whose activities involve the regular and systematic monitoring of data subjects on a large scale, or organisations that process what is known as sensitive personal data on a large scale. At Langdon Customs and Excise Solutions Ltd, we have appointed a Senior Manager to this role.

#3 Demonstrate accountability in all processing activities

Langdon Customs and Excise Solutions Ltd has implemented an information security program consisting of policies and procedures that define how system information is entered, managed, and protected. Langdon’s current information security program is further specified in our Master Subscription Agreement (MSA) as well as our Data Processing Agreement (DPA). In particular, Langdon commits to monitor, analyse and respond to security incidents in a timely manner in accordance with Langdon’s standard operating procedure, which sets forth the steps that Langdon employees must take in response to a threat or security incident. Langdon continues to invest in a growing global security capability.

#4 Check cross-border data flows

Both the Data Protection Directive and the GDPR permit personal data transfers outside of the EU subject to compliance with defined conditions, including conditions for onward transfer. When a Client contracts with Langdon, we can enter into a Data Processing Agreement (DPA) with applicable Clients. In the DPA, we agree with our Client on the terms for the compliant processing of Client personal data, including the description of our security and data privacy policy and the EU standard contractual clauses.

#5 Prepare for data subjects exercising their rights

Within the Langdon Platform, our Clients use the personal data of their users to interact with each other in order to better manage their data analytics. As such, our Clients will look to Langdon as service provider and data processor to offer functionalities within the Langdon Platform that enable our Clients to achieve compliance. Our internal product design processes are focused on the user and their positive and productive experience on the Langdon Platform. In light of GDPR, Langdon periodically reviews the Langdon Platform features in order to validate that the Langdon platform provides the required functionalities to our Clients.

Staying current

Ensuring the privacy and security of our Client’s data is an ongoing commitment for Langdon. We will continue to update this document to reflect any GDPR-related developments.