Data Protection Policy of Conker Cloud Innovations Ltd
People, risks and responsibilities
Conker Group places high importance on the legal, and fair handling of all personal data, respecting the rights, privacy, and trust of all individuals with whom it deals. The General Data Protection Regulation (GDPR) will apply from 25 May, 2018 when it supersedes the UK Data Protection Act 1998 (DPA). This Policy aims to ensure compliance and responsibilities regarding the collection, processing, transfer, and storage, of personal data. Conker Group, its employees, contractors, or other parties working on behalf of the Company must comply to the principles and procedures set out within this policy.
1. Policy Scope
This policy applies to
- All staff of Conker Group
- All contractors and other people working on behalf of Conker Group
- All customers, suppliers - and third parties with whom the company works
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Plus any other information relating to individuals
2. Data protection risks
This policy helps to protect Conker Group and those listed in the above Policy Scope from some very real data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with Conker Group has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
However, these people have key areas of responsibility:
- The Conker Group CEO is ultimately responsible for ensuring that Conker Group companies meet their legal obligations.
The Conker Group Data Controller is responsible for:
- Keeping the CEO updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data Conker Group holds about them (also called ‘subject access requests’).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
The Chief Software Engineer is responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software is functioning properly.
- Evaluating and approving any third-party services the company is considering using to store or process data. For instance, cloud computing services.
4. 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.
- Conker Group 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.
- Personal data should not be disclosed to unauthorised people, either within the company or externally.
- Data should be regularly reviewed and updated if it is found to be out of date. If no longer required for its purpose, it should be deleted and disposed of.
- Employees should request help from their line manager or the Chief Software Engineer if they are unsure about any aspect of data protection.
5. Data storage
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the data controller.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
- When not in use, any data that has been printed out on paper should be kept in a locked drawer or filing cabinet.
- Employees should make sure any data printed on paper is not left where unauthorised people could see it, like on a printer.
- Data that is stored or printed on paper 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 a CD or USB), these should be kept locked away securely when not being used.
- Data should only be stored on designated drives and servers, and should only be uploaded to 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.
- Personal data should never be saved directly to personal laptops or other personal mobile devices like tablets or smartphones, except where expressly required - e.g. email address or phone number to allow direct contact.
- All servers and computers containing data should be protected by approved security software and a firewall.
6. Data use
Personal data is of no value to Conker Group 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 left 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.
- Data must be encrypted before being transferred electronically to any authorised external contacts.
- Personal data should never be transferred outside of 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.
7. Data accuracy
The law requires Conker Group 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 Conker Group 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.
- Conker Group will make it easy for any individual to update the information that Conker Group holds about them.
- 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.
8. Subject access requests
All individuals who are the subject of personal data held by Conker Group 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 an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the data controller at email@example.com. The data controller can supply a standard request form, although individuals do not have to use this.
The data controller will always verify the identity of anyone making a subject access request before handing over any information and will aim to provide the relevant data within 14 days.
9. Disclosing data for other reasons
In certain circumstances, the Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Conker Group will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the CEO and from the company’s legal advisers where necessary.
10. Data Breach
If any member of Conker Group become aware of any actual or possible personal data breach they must notify the data controller immediately. The data controller along with the Chief Software Engineer are responsible for investigating any actual or possible data breaches and whether any notification obligations apply.
Responding to the breach will include:
- Ensuring the breach is contained as soon as possible and the appropriate steps are taken immediately to minimise the effect of the breach
- Assessing the level of risk to any individuals as soon as possible
- Gathering and collating information from all relevant sources
- Notifying the CEO, and individuals of the breach when necessary
An Incident Report will be completed as part of the reporting process. The report will include full and accurate details of the incident, when the breach occurred, if the data relates to people or company data, and how many individuals are involved.