Yoshki Ltd 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 Yoshki Ltd:
- 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
To comply with data protection law, personal information is collected and used fairly, stored safely and not disclosed unlawfully.
Data protection rules state that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, 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
This policy applies to:
- The head office of Yoshki Ltd
- All branches of Yoshki Ltd
- All staff and volunteers of Yoshki Ltd
- All contractors, suppliers and other people working on behalf of Yoshki Ltd
It applies to all data that the company holds relating to identifiable individuals. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- …plus any other information relating to individuals
Everyone who works for or with Yoshki Ltd 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 Yoshki Ltd meets its legal obligations.
The data protection officer, T. Rogers, is responsible for:
o Keeping the board updated about data protection responsibilities, risks and issues.
o Reviewing all data protection procedures and related policies, in line with an agreed schedule.
o Arranging data protection training and advice for the people covered by this policy.
o Handling data protection questions from staff and anyone else covered by this policy.
o Dealing with requests from individuals to see the data Yoshki Ltd holds about them (also called ‘subject access requests’).
o Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
The IT manager, T. Walton, is responsible for:
o Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
o Performing regular checks and scans to ensure security hardware and software is functioning properly.
o Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
The marketing manager, D. Whittaker, is responsible for:
o Approving any data protection statements attached to communications such as emails and letters.
o Addressing any data protection queries from journalists or media outlets like newspapers.
o 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.
- Yoshki Ltd 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 IT manager or 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 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 CD or DVD), 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 smartphones.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Yoshki Ltd 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 computers. Always access and update the central copy of any data.
SUBJECT ACCESS REQUESTS
All individuals who are the subject of personal data held by Yoshki Ltd 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.
Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 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 Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Yoshki Ltd 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.
APPENDIX A: SMART BADGE SPECIFIC DATA SECURITY POLICY
A Smart Badge owner has their image(s) hosted and managed by Yoshki Ltd, along with an associated list of approved companies and website addresses. Typically, this data is already in the public domain. However, data security still aims to comply with data protection laws, and follows good practice.
- The badge images can only be updated when approved by at least two service administrators. (Through the administration interface a single user can’t change any image.)
- Administration access is restricted by IP address.
- Administration access uses 2-factor authentication.
- Server and database passwords are strong and changed at intervals.
- Database backups are encrypted.
- Passwords are not stored in plain text but are hashed and salted.
- All admin functionality is forced to run over SSL.
All images, when added to a website, have Google Analytics code to record anonymous statistics including:
- How often an image is viewed.
- How often an image is clicked.
- If an image click generated an ‘approved’ or ‘not approved’ message.
RESILIENCE AND UPTIME
Services provided by Yoshki Ltd are hosted on the Level3 Content Delivery Network, offering reliable, worldwide distribution of content, over a network favoured by companies such as the BBC and Apple Inc.
APPENDIX B: PARTNERS
Yoshki Ltd uses key partners for Internet hosting, worldwide content delivery, and analytics: