Data Protection Policy

Data360 needs to gather and use certain information about individuals.

This can include customers, suppliers, business contacts, employees and other people the organization 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.

This data protection policy ensures :

  • 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 Data Protection Act 1998 describes how organizations — including — 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 Data Protection Act is underpinned by eight important principles. These say 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
  • Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

Policy Scope

This policy applies to:

  • The head office of Data360
  • All branches of Data360
  • All staff and volunteers of Data360
  • All contractors, suppliers and other people working on behalf of Data360

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • …plus any other information relating to individuals

Data Usage

Data360 may rent or license or sell any or all PII (Personal Identifiable Information) that we have collected as a result of our Online Survey/Registration Portal. PII (Linked or Delinked) maybe provided to 3rd parties for marketing and promotional campaigns. This may include but not limited to: Direct Mail Campaign, Email Campaign, Telemarketing Campaign or Display Ad Campaign.

IP Address and Cookie

Data360 may collect and aggregate an individual’s IP Address and or Cookie as a result of completing Online Survey or Registration Portal. IP Address and or Cookie may be: Rented/Sold or Licensed to 3rd parties for marketing/branding and advertising campaign

General Staff Guidelines

  • The only people with access to your PII are those who need it for their work.
  • Data will not be shared informally. When access to confidential information is required, employees can request it from their line managers.
  • CMSwill provide training to all employees to help them understand their responsibilities when handling data.
  • Employees shall keep all data secure, by taking sensible precautions and following the guidelines below.
  • In particular, strong passwords are used and they are never to be shared.
  • Personal data shall not be disclosed to unauthorized people, either within the company or externally.
  • Data shall 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 shall request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data Storage

When data is stored on paper, it shall 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 shall make sure paper and printouts are not left where unauthorized people could see them, like on a printer.
  • Data printouts shall be shredded and disposed of securely when no longer required.

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

  • Data shall 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 shall be kept locked away securely when not being used.
  • Data shall only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
  • Servers containing personal data shall be sited in a secure location, away from general office space.
  • Data shall be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
  • Data shall never be saved directly to laptops or other mobile devices like tablets or smartphones.
  • All servers and computers containing data shall be protected by approved security software and a firewall.

Data Use

  • When working with personal data, employees shall ensure the screens of their computers are always locked when left unattended.
  • Personal data shall not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • Data shall be encrypted before being transferred electronically. The IT manager can explain how to send data to authorized external contacts.
  • Personal data shall never be transferred outside of the European Economic Area.
  • Employees shall not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data Accuracy

  • Data will be held in as few places as necessary. Staff shall not create any unnecessary additional data sets.
  • Staff shall take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
  • CMS will make it easy for data subjects to update the information holds about them. For instance, via the company website.
  • Data shall 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 owners responsibility to ensure marketing databases are checked against industry suppression files every six months.

Consumer Access Requests

Please email [email protected]if you would like to Opt Out and stop receiving 3rd party marketing and promotional messages, would like to review your data record, or would like to amend, alter and or edit your data record.

How Your Personal Data May Be Used

Data360 may Rent/License/Sell the PII (Personal Identifiable Information) whether PII has been de-linked or not to 3rd parties for marketing, branding advertising campaign. As a result of providing your individual and personal consent to Data360 you may receive 3rd party marketing messages.

Your individual PII may be used as a part of an Email Campaign, TeleMarketing Campaign, Fax Campaign, Direct Mail or Display Ad Campaign.