Context and overview
Eurolink Technology takes data protection very seriously and in line with the General Data Protection Regulation we aim to be transparent with the data that we hold. Ensure that all personal data is collected with the correct permissions and stored securely.
Policy prepared by:
Approved by board / management on:
21st May 2018
Policy became operational on:
24th May 2018
Next review date:
23rd May 2019
Eurolink Technology 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 Eurolink Technology:
• Complies with data protection law and follow good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach
Data protection law
The General Data Protection Regulation describes how organisations — including Eurolink Technology— 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.
Principles relating to processing of personal data
Personal data shall be:
A. processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
B. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);
C. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
D. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
E. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
F. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
Lawfulness of processing
Processing shall be lawful only if and to the extent that at least one of the following applies:
A. the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
B. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
C. processing is necessary for compliance with a legal obligation to which the controller is subject;
D. processing is necessary in order to protect the vital interests of the data subject or of another natural person;
E. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
F. processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
Conditions for consent
A. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data.
B. If the data subject’s consent is given in the context of a written declaration which also concerns other matters, the request for consent shall be presented in a manner which is clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language. Any part of such a declaration which constitutes an infringement of this Regulation shall not be binding.
C. The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. It shall be as easy to withdraw as to give consent.
D. When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the processing of personal data that is not necessary for the performance of that contract.
People, risks and responsibilities
This policy applies to:
• The head office of Eurolink Technology
• All branches of Eurolink Technology
• All staff and volunteers of Eurolink Technology
• All contractors, suppliers and other people working on behalf of Eurolink Technology
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. 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 Eurolink Technology 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 Eurolink Technology 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 Eurolink Technology meets its legal obligations.
The Data Protection Officer, Carl Nelson, 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 individuals to see the data Eurolink Technology 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.
• 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.
• Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
The Head of Service Desk, Duwayne Lake, 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.
The Head of CRM, Sales and Marketing, Chris Reile, is responsible for:
• 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.
• Eurolink Technology 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, it should be deleted and disposed of.
• 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 Data Protection Officer.
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 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 a DVD or USB Drive), 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 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.
Personal data is of no value to Eurolink Technology 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 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.
The law requires Eurolink Technology 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 Eurolink Technology 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.
• Eurolink Technology will make it easy for data subjects to update the information Eurolink Technology holds about them. For instance, via the company website.
• 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.
• It is the Head of Sales, CRM & Marketing’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject Access requests
All individuals who are the subject of personal data held by Eurolink Technology 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 protection officer at firstname.lastname@example.org. The data protection officer can supply a standard request form, although individuals do not have to use this.
The data protection officer will aim to provide the relevant data within 1 month.
The data protection officer will always verify the identity of anyone making a subject access request before handing over any information.
Unfounded, excessive or repeated requests for the same data will be charged a fee.
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, Eurolink Technology will disclose requested data. However, the Data Protection Officer will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Eurolink Technology 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 these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.
This is available on request.