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- Implemented a Data Protection Impact Assessment process - this is essentially a risk assessment to help us identify and minimise the risk of a data breach.
- Documented and checked all the sub-processors and third-party integrations - we've been making a list of all the third-party companies and services we use to deliver SubHub and our related services, and making sure that they are all GDPR compliant as well.
- Created a detailed register of our data processing activities - we've documented exactly what we use personal data for and how it's stored and processed.
- Moved our database to EU data center - we were storing our database with a US datacenter, but we've moved to an EU one for better control.
- Audited our back up policy - we've made stricter rules for how long we store personal data and for what reasons.
- Done a data clean up - all outdated and obsolete data (from past clients, out-of-date backups etc) has been deleted from our systems.
- Updated our privacy policy, cookie policy and terms and conditions - all our policies are now officially GDPR compliant.
- Updated our email sign up processes - our sign-up forms are currently being updated and clarified to help us get affirmative consent.
- Update our free trial sign up processes - our free trial sign up process is also being updated to include marketing consent and our new policies.
- Re-optin campaign to all our mailing lists - we'll be sending out a re-optin campaign to all our mailing lists, encouraging subscribers to resubscribe to ensure that the data we hold is up-to-date and we have explicit marketing consent.
- Created a procedure to deal with data access and update requests - a basic procedural document to show how we will deal with these sorts of requests.
- Created a data breach plan document - a procedural document to show what we'll do in the case of a data breach.
- Updated SubHub platform - so that our clients have the capabilities to enable cookie notifications, online forms for data access requests, and other actions.