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Data security policy
This policy outlines behaviours expected of employees when dealing with data and provides a classification of the types of data with which they should be concerned.
Techfellow Ltd must protect restricted, confidential or sensitive data from loss to avoid reputation damage and to avoid adversely impacting its customers. The protection of data in scope is a critical business requirement, yet flexibility to access data and work effectively is also critical.
It is not anticipated that this technology control can effectively deal with the malicious theft scenario, or that it will reliably detect all data. Its primary objective is user awareness and to avoid accidental loss scenarios. This policy outlines the requirements for data leakage prevention, a focus for the policy and a rationale.
These measures must be applied to all protected personal or otherwise sensitive data. Protected personal data is defined at Annex A and is any material that links an identifiable individual with information whose release would put them at significant risk of harm or distress. It also covers any source of information relating to 1,000 or more individuals that is not in the public domain, even if the information about an individual is not considered likely to cause harm or distress.
- During the course of business the Company may hold personal data relating to individuals. The General Data Protection Regulation (GDPR) requires the Company to maintain strict security in relation to personal data held by it relating to individuals whether those individuals are clients or suppliers, or prospective clients or suppliers, or prospective employees;
- No information referring to private individuals should be taken or sent from the Company’s offices and each employee must understand the importance of not divulging any such information to persons other than other employees within the Company. Employees asked to transfer personal data to recipients outside the Company (e.g. giving out a home telephone number of an employee or details of a customer) should satisfy themselves that the transfer is authorised by the Company before carrying out such a request;
- Employees should be aware that it is a criminal offence to access or disclose personal data held by the Company without authority;
- Employees who have access to or control over personal data held by the Company, e.g. employee records/lists or details relating to customers or private individuals, should ensure that access to the data within the Company is restricted on a need to know basis and that it is stored in accordance with the data security provisions set out below;
- Protected Personal Data (as defined in Annex A) which is held on paper must be locked away when not in use and offices in which it is held must be secured;
- All computers (whether remote or otherwise) are password protected, configured so that functionally is minimised to it’s intended business use only, and have up to date software patches and anti-virus software;
- All material that has been used for protected data should be subject to controlled disposal;
- All laptops, drives or removable electronic data media containing personal data should be encrypted. Laptops and drives or any other removable electronic media containing protected personal data are to be held in locked cabinets or drawers when not in use;
- It is company policy that protected personal data may not be transferred to third party owned laptops, PCs, USB keys, external drives and any other removable electronic media;
- As part of the Company’s terms and conditions of employment, employees consent to the Company holding and using personal data relating to them. Personal data includes names and addresses, bank details, health records and most of the information that it needs to hold about employees for employment purposes. On joining Techfellow Ltd, the employee will be required to notify the Company of such personal details. Any relevant changes to such personal information must be notified to the management;
- For the purposes of the General Data Protection Regulation (GDPR), the Company needs to specify the purposes for which we will use that information. The Company will of course only use it for legitimate purposes. Those purposes include:
o Complying with obligations to its employees. It needs personal data so it can perform activities such as contacting and paying employees, and complying with its obligations under health and safety regulations;
o Assessing employees, their performance and suitability for particular roles;
o Doing anything for the benefit of welfare of employees, their families and dependants;
o Complying with its obligations under the general law, e.g. in relation to taxation, social security, or law enforcement;
o Providing information about employees to those who require it in connection with services that they provide to it or we to them, or who do or may own the Company or who may need it in connection with the assumption by them of responsibility for any of its employees (e.g. in outsourcing arrangements);
o The prosecution or defence of any legal proceedings
- Information risk management
The data protection measures outlined in this policy are to be implemented through the following processes:
o Initial induction training for all staff;
o Regular refresher training for all staff, as required;
o Publication of data protection policy in the staff handbook as well as quarterly risk assessments.
Definition of protected personal data
As a minimum, personal data includes all data falling into either category A or B below:-
A: Any information that links one or more identifiable living person with private information about them
There should be protection for a data set that includes:-
- One or more of the pieces of information through which an individual may be identified (name, address, telephone number, driving licence number, date of birth, photograph etc.), combined with;
- Information about that individual whose release could case harm or distress, including:-
o DNA or finger prints;
o Bank/financial/credit card details;
o National Insurance number;
o Passport number/information on immigration status;
o Travel details (for example at immigration control, or Oyster records);
o Tax, benefit or pension records;
o Place of work;
o School attendance/records;
o Conviction/prison/court records/evidence;
o Groups/affiliations/political or other sensitive personal data as defined by the GDPR.
Note: this is not an exhaustive list.
B: Any source of information about 1,000 identifiable individuals or more, other than information sources from the public domain.
Note that this is a minimum standard. Information on smaller numbers of individuals may justify protection because of the nature of the individuals, source of the information, or extent of information.