This Data Protection Policy sets out how we handle the personal data of our customers, suppliers, employees, workers and other third parties regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other data subject.
This Data Protection Policy applies to all Company personnel and sets out what we expect from you in order for the Company to comply with applicable law. Your compliance with this Data Protection Policy is mandatory. Any breach of this Data Protection Policy may result in disciplinary action.
We adhere to the principles relating to processing of personal data set out in the GDPR which require personal data to be:
We are responsible for and must be able to demonstrate compliance with the data protection principles listed above.
Personal data must be collected only for specified, explicit and legitimate purposes. It must not be further processed in any manner incompatible with those purposes.
You cannot use personal data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the data subject of the new purposes and they have consented where necessary.
You must ensure that when personal data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company’s data retention guidelines.
Personal data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.
You must check the accuracy of any personal data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date personal data.
Personal data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.
You must not keep personal data in a form which permits the identification of the data subject for longer than needed for the legitimate business purpose for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.
You will take all reasonable steps to destroy or erase from our systems all personal data that we no longer require in accordance with all the Company’s applicable records retention policies. This includes requiring third parties to delete such data where applicable.
You will ensure data subjects are informed of the period for which data is stored and how that period is determined in any applicable privacy notice.
Protecting Personal Data
Personal data must be secured by appropriate technical and organisational measures against unauthorised or unlawful processing, and against accidental loss, destruction or damage.
You must follow all procedures and technologies we put in place to maintain the security of all personal data from the point of collection to the point of destruction. You may only transfer personal data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.
You must maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:
Reporting A Personal Data Breach
The GDPR requires data controllers to notify any personal data breach to the applicable regulator and, in certain instances, the data subject.
The GDPR restricts data transfers to countries outside the EEA in order to ensure that the level of data protection afforded to individuals by the GDPR is not undermined. You may only transfer Personal Data outside the EEA if one of the following conditions applies:
Data subjects have rights when it comes to how we handle their personal data. These include rights to:
The Data controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The data controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.
The GDPR requires us to keep full and accurate records of all our data processing activities.
We are required to ensure all company personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.
We are subject to certain rules and privacy laws when marketing to our customers.
For example, a data subject’s prior consent is required for electronic direct marketing (for example, by email, text or automated calls). the limited exception for existing customers known as “soft opt in” allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.
The right to object to direct marketing must be explicitly offered to the data subject in an intelligible manner so that it is clearly distinguishable from other information.
A data subject’s objection to direct marketing must be promptly honoured. if a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.
Generally we are not allowed to share personal data with third parties unless certain safeguards and contractual arrangements have been put in place.
We may only share the personal data we hold with another employee, agent or representative of our group (which includes our subsidiaries and our ultimate holding company along with its subsidiaries) if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions.
Legal Counsel
Rahul Keshap, Esquire
Shuru Law LLC
