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Data protection policy

Context and overview

Key details

Policy prepared by: Dorcas Réamonn

Policy became operational on: 25th May 2018 .

Next review date: 25th August 2018

Introduction

Zonua 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 Zonua:

Data protection law

The General Data Protection Regulation 2016/679 describes how organisations — including Zonua — 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 eight important principles. These say that personal data must:

  1. Be processed fairly and lawfully
  2. Be obtained only for specific, lawful purposes
  3. Be adequate, relevant and not excessive
  4. Be accurate and kept up to date
  5. Not be held for any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. Not be transferred outside the EU, unless that country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope

This policy applies to:

It applies to all data that the company holds relating to living individuals, even if that information technically falls outside of the General Data Protection Regulation 2016/679. This can include:

Data protection risks

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

Responsibilities

Everyone who works for or with Zonua 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:

General staff guidelines

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

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

Data use

Personal data is of no value to Zonua 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:

Data accuracy

The law requires Zonua 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 Zonua 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.

Subject access requests

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

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 address]. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals cannot be charged to honour a subject access request. The data controller will aim to provide the relevant data within 30 days.

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, 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, Zonua 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.

Providing information

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

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

. . . this is just to validate that you are a human.

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