July 2018

Now what?

Ultimately time will tell how the GDPR crosses the big

pond and makes a difference in policies in the U.S.

Generally, the initiative is a win for the individual. It

embraces practices that embody how a person’s data should

be handled. And although cities and water districts may not

need to act now, staying informed is critical. You don’t want

to be caught unprepared for yet another regulation!

handles customer data, your system should start

becoming familiar with these initiatives, if at least

at a high level bird’s eye view.

What should you know?    

While the goals of this regulation are well-

intended, its wording leaves almost no room for

very many entities to do anything with data at all.

Many have described GDPR as a “moving target”

and no one knows how it will play out! While you

have fun watching on the sidelines, it’s important

to think about how in the future, stringent data

handling regulation might affect your procedures.

The most important preparation you can make

is to take inventory of all of your data. How do you collect

it? Where is it stored? Who has access to it? If you want to

go further, read “Data Privacy and Protection: Shut the front

door. And the back door”. See pages 86-87 in the March

2018 issue of The Kansas Lifeline.

You should know a few key terms that might be recycled

if the U.S. implements similar regulation.

Data Controller: This is you. It's a person/entity who

decides the purpose for which any personal data is to be

processed and the way in which it is to be processed.

Data Processor: These are third parties that process data

on behalf of the Data Controller, such as your website,

billing software, etc.

Transparency: You have an obligation to inform your

customers of how you use their data.

Consent: For some data, you can use it how you want if

you obtain the user’s consent. This is done explicitly, not by

making them uncheck a box to be excluded.

Think OPT IN, rather than opt out.

Performance of Contract: You might have

an important reason to use data, for example,

if you cannot fulfill an agreement with them


Privacy Notice: This is a thorough and

transparent explanation of your system’s

policies for using data. It’s important to have

one displayed prominently and available,

such as on a link on your website or in


Legitimate Interest: You might have an

important reason to use data if there is a legal

obligation or other mutual interest. This is a

vague concept that needs careful assessment

and justification to use without the users’


Right to be forgotten: The right to erasure

of personal data or “the right to be forgotten”

enables an individual to request the deletion

or removal of personal data whether there is

no compelling reason for its continued


Since 1997, Jen Sharp (JenSharp.com) has served

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