SNOMED International

GDPR Compliance Statement


The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018. The GDPR aims to strengthen the security and protection of personal data in the EU and will replace the current European Privacy Directive.

Your privacy is important to us. SNOMED International is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR.

This statement outlines our commitment to safeguarding the personal information we store or process, as well as our compliance and alignment to the GDPR principles. It includes the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure ongoing compliance.

If you have any questions about our preparation for the GDPR, please contact

Our Preparation

SNOMED International already had robust information security policies in place, however it is our aim to be fully compliant with the GDPR by 25th May 2018.

  • Information Audit - we have carried out an organisation-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed. Where personal data is stored or transferred outside the EU, we have ensured that robust procedures and safeguards are in place that are Privacy Shield/GDPR compliant to ensure the security and integrity of that data.

  • Policies & Procedures - we have revised existing and implemented new data protection policies and procedures to meet the requirements and standards of the GDPR, including:

    • Data Protection – our main policy and procedure document for data protection is being updated to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.

    • Data Retention & Erasure – we are updating our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.

    • Data Breaches - our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate any personal data breach at the earliest possible time. Our processes will ensure that the data subject and the relevant supervising authority are notified of any data breach affecting personal data within 48 hours of detection.

    • Subject Access Request (SAR) - we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.

    • Obtaining Consent - we have revised our procedures for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and processes to change consent at any time.

  • Legal Basis for Processing - we have been reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. The majority of personal data held by SNOMED International is either used for licence/contractual purposes or to identify and maintain access/security to our products and services, therefore such data is stored and processed under the basis of ‘legitimate interest’ and does not require any additional consents. Where this is not the case the required explicit consents will be obtained from those data subjects affected. Individuals still retain the right to change their consent at anytime.

  • Privacy Policies - we have revised our Privacy Policies to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.

  • Direct Emailing - we are revising the wording and processes for direct marketing, including clear opt-in mechanisms for email subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing emails.

  • Data Processor Agreements - where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, etc), we have drafted compliant Data Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations.

Data Subject Rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide the ability via to allow an individual’s right to access any personal information that SNOMED International processes about them and to request information about:

  • What personal data we hold about them

  • The purposes of the processing

  • The categories of personal data concerned

  • The recipients to whom the personal data has/will be disclosed

  • How long we intend to store your personal data for

  • If we did not collect the data directly from them, information about the source

  • The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this

  • The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct emails from us

  • The right to lodge a complaint and who to contact in such instances

Information Security

SNOMED International takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction.

GDPR Roles and Employees

SNOMED International has appointed a data protection team to develop, implement and maintain our compliance with the new GDPR. The team is responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.

SNOMED International understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and is involving its employees in our preparation plans. We will be implementing an employee training program specific to the Regulation which will be provided to all employees prior to 25th May 2018, and forms part of our induction and annual mandatory training program.

If you have any questions about our preparation for the GDPR, please contact