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Data protection policy – Rev 1.0

Context and overview

 

Introduction

Vivian Corporation needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards – and to comply with the law.

 

Why this policy exists

This data protection policy ensures that Vivian Corporation:

  • Complies with data protection law and follows good practice
  • Protects the rights of staff, customers and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risk of a data breach

 

General Data Protection

The General Data Protection Regulation 2018 describes how organisations – including Vivian Corporation must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The General Data Protection Regulation is underpinned by seven important principles:

  1. lawful, fair and transparent processing – this principle emphasizes transparency for all EU data subjects.
  2. Purpose limitation – organizations need to have a lawful and legitimate purpose for processing the information in the first place.
  3. Data minimization – this principle instructs organisations to ensure the data they capture is adequate, relevant and limited.
  4. Accurate and up to date processing – data controllers must make sure information remains accurate, valid and fit for purpose.
  5. Limitation of storage in the form that permits identification – This principle discourages unnecessary data redundancy and replication.
  6. Confidential and secure – this principle protects the integrity and privacy of data by making sure it is secure.
  7. Accountability and liability – this principle ensures that organizations can demonstrate compliance.

 

People, risks and responsibilities

Policy scope

This policy is a company wide policy and applies to:

  • All shareholders and employees of Vivian Corporation
  • All contractors, suppliers and other people working on behalf of Vivian Corporation

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the General Data Protection Regulation 2018.  This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • ….plus any other information relating to individuals

 

Data protection risks

This policy helps to protect Vivian Corporation from some very real data security risks, including:

  • Breaches of confidentiality. For instance, information transferred or shared inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the company uses their personal data.
  • Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

 

General staff guidelines

  • The only people able to access data covered by this policy should be those who need it for their work.
  • Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
  • Vivian Corporation will provide training to all employees to help them understand their responsibilities when handling data.
  • Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
  • In particular, strong passwords must be used and they should never be shared.
  • Users will be prompted to change their passwords every three months.
  • Employees must always log off when computer is not in use.
  • Personal data should not be disclosed to unauthorised people, either within the company or externally.
  • Access to personal data is limited to those who have a genuine business need, to know it.
  • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
  • Employees should request help from their line manager if they are unsure about any aspect of data protection.

 

 

Data storage

These rules describe how and where data should be safely stored.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it and must be shredded once no longer needed.

 

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
  • Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared between employees.
  • If data is stored on removable media (like CD or DVD), these should be kept locked away when not being used.
  • Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing services.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing data should be protected by approved security software and a firewall.

 

 

 

 

Data use

Personal data is of no value to Vivian Corporation unless the business can make use of it.  However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

  • When working with personal data, employees should ensure the screens of their computers are always locked when unattended.
  • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • Personal data should never be transferred outside the European Economic Area.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

 

 

Data accuracy

The law requires Vivian Corporation to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort Vivian Corporation should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
  • Vivian Corporation will make it easy for data subjects to update the information Vivian Corporation holds about them by sending an email to: gdpr@viviancorp.com
  • Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.

 

Subject access requests

All individuals who are the subject of personal data held by Vivian Corporation are entitled to:

  • Ask what information the company holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date.
  • Be informed how the company is meeting its data protection obligations.

 

If any individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email on gdpr@viviancorp.com

 

 

Disclosing data for other reasons

 

In certain circumstances, the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

 

Under these circumstances, Vivian Corporation will disclose requested data.  However, management will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

 

Providing information

 

Vivian Corporation aims to ensure that individuals are aware that their data is being processed, and that they understand:

 

  • How the data is being used
  • How to exercise their rights

To this end the company has a privacy statement, setting out how data relating to individuals is used by the company.

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