Data Protection PolicyOctober 4, 2018
Easy logger needs to gather and use certain information about customers.
This can include statistics on smartphone usage, apps installed / uninstalled, location, Gforce, app usage activity. Tracking calls and texts sent or received.
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.
As all the Easy logger infrastructure is on the Microsoft Azure platform Azure data security policies apply to us. https://www.microsoft.com/en-us/TrustCenter/Security/default.aspx
Why this policy exists
This data protection policy ensures Easy logger:
- Complies with data protection laws and follow good practice
- Protects the rights of customers, staff, and partners
- Is open about how it stores and processes customers’ data
- Protects itself from the risks of a data breach
Data protection law
The Data Protection laws in the United States and the European Union (GDPR) describes how organizations — including Easy logger— 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.
Important principles of the law say personal data must:
- Be processed with customer knowledge fairly and lawfully
- Be obtained only for specified, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
People, risks, and responsibilities
This policy applies to:
- The head office of Easy logger
- All branches of Easy logger
- All staff and volunteers of Easy logger
- All contractors, suppliers and other people working on behalf of Easy logger
It applies to all data that the company holds relating to identifiable customers, even if that information technically falls outside of the Data Protection Act 1998. This can include:
- Names of people
- Postal addresses
- Email addresses
- Telephone numbers
- Assessment information
- Job goals
- Project details
Data protection risks
This policy helps to protect Easy logger from some very real data security risks, including:
- Breaches of confidentiality. For instance, the information being given out inappropriately.
- Failing to offer choice. For instance, all customers 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 Easy logger 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 board of directors is ultimately responsible for ensuring that Easy logger meets its legal obligations.
- The [data protection officer], Mehul Grant, is responsible for:
- Keeping the board updated about data protection responsibilities, risks, and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- 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 customers to see the data Easy logger 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 [Easy logger IT Team] 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 any third-party services the company is considering using to store or process data. For instance, cloud computing services.
- Extracting data for customers who request their information to be downloaded.
- Deleting data for customers who request their data to be deleted.
- The [executive board of directors], is responsible for:
- Approving any data protection statements attached to communications such as emails and letters.
- Addressing any data protection queries from journalists or media outlets like newspapers.
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
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.
- Easy logger 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 unauthorized people, either within the company or externally.
- Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT team.
When data is stored on paper, it should be kept in a secure place where unauthorized 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 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 unauthorized people could see them, like on a printer.
- Data printouts should be shredded and disposed of securely when no longer required or has been requested by the customer to be destroyed.
When data is stored electronically, it must be protected from unauthorized access, accidental deletion, and malicious hacking attempts:
- Each customer will have separation of data from other customers via a domain that is exclusively reserved for that customer e.g. customername.Easy logger.com.
- All data is to be 256 bit encrypted during transit, sensitive aspects of the data would be encrypted at rest.
- All to and fro access from the cloud is to pass through Application level firewalls.
- Data should be protected by strong passwords that are changed regularly and never shared among employees.
- If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
- Data should only be stored on approved cloud computing services platform at Microsoft Azure.
- Servers containing personal data should be on the approved cloud computing services platform at Microsoft Azure, 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 smartphones.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Easy logger 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. The IT manager can explain how to send data to authorized external contacts.
- Personal data should never be transferred outside the approved cloud computing services platform.
- Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
- When requested data is to be downloaded from all systems and transmitted to the customer in the mode requested.
- When requested all customer data is to be purged from the active system, backups and all offline copies.
The law requires Easy logger 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 Easy logger 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.
- Easy logger will make it easy for data subjects to update the information Easy logger holds about them. For instance, via the company cloud portal.
- 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 companies who are the subject of data held by Easy logger are entitled to:
- Ask what information Easy logger holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how Easy logger 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 the customer should be made by email, addressed to the data controller at [email protected]. The data controller can supply a standard request form, although customers 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.
Disclosing data for other reasons
In certain circumstances, Data Protection laws allow personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Easy logger will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Easy logger aims to ensure that customers are aware that their data is being processed and that they understand:
- How the data is being used
- How to exercise their rights