GDPR

Introduction

SpocLog hereinafter referred to as ‘we’, ‘our’, ‘the company. The security and management of data is important to ensure that we can function effectively and successfully for the benefit of our stakeholder, customers and for the community. In doing so, it is essential that people’s privacy is protected through the lawful and appropriate use and handling of their personal information. The company has a responsibility to adhere to the Data Protection Principles outlined in all the applicable privacy and data protection laws, and to this Personal Data Protection Policy and any other policies which may be formulated for data protection and data privacy purposes by the company.

 

Aim

This policy aims to protect personal data of the various stakeholders connected to our organization. This Policy sets forth the basic principles by which the Company processes the personal data of consumers, customers, suppliers, business partners, employees and other individuals, and indicates the responsibilities of its business departments and employees while processing personal data.
This Policy is also intended to provide adequate safeguards for the processing of Personal Data entrusted to the company and transferred from countries requiring such protections. This is to enable the company to transfer Personal Data wherever it is needed around the globe to enable and support its internal business processes or enable services and product functionality and improvement. In order to do this, the company may formulate and describe certain additional obligations and legal rights in circumstances where data protection laws and regulations of other jurisdictions are applicable.

 

Scope

This policy control applies to all systems, people and processes that constitute the organization’s information systems, including board members, directors, employees and other third parties who have access to personal data available within the company.
The company is also committed to ensure that its employees conduct themselves in line with this, and other related, policies. Where third parties process data on our behalf, the Company will ensure that the third party takes such measures in order to maintain the Company’s commitment to protecting data. The company understands that it will be accountable for the processing, management and regulation, and storage and retention of all personal data held in the form of manual records and on computers.

 

Definitions

Personal data: It is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.
Special categories of personal data: It is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).
Data processing: It is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Any other term not defined herein, shall have the same meaning as defined in the Regulation (EU) 679/2016 (General Data Protection Regulation).

 

Reference Documents

  • IT Security Policy
  • Privacy Notice
  • Cross Border Personal Data Transfer Procedure
  • Data Retention Policy
  • Personal data breach notification procedure
  • Employee Privacy Notice
  • Data Subject Access Request Procedure

 

Types of Personal Data Processed

Personal data is kept in personnel files or within the electronic records of SpocLog the following types of data may be held by the Company, as appropriate, on relevant individuals:

A. Members and Clients data

  • First Name, Last name
  • Job title & Company
  • Email address
  • Phone numbers
  • Area of Interests
  • Country of residence

B. Human Resource Data

  • Name, address, phone numbers – for individual and next of kin
  • CVs and other information gathered during recruitment references from former employers,
  • National Insurance numbers, job title, job descriptions and pay grades,
  • Conduct issues such as letters of concern,
  • Disciplinary proceedings
  • Holiday records
  • Internal performance information
  • Medical or health information sickness absence records
  • Tax codes
  • Employment training details.

C. Website Visitor Data

  • Visitors IP Data
  • Data and time of website visit
  • Pages visited and navigation on the website
  • Browser being used
  • County of accessing website
  • Language of the browser being used
  • Words searched for

D. Inquiries

  • Personal data stated in the form- Name, address, phone number, country
  • Subject of Inquiry
  • Payment Information
  • Personal details (Name on the card, billing address)
  • Payment details (card numbers, card type)

We are using a secure third party to manage transactions and ecommerce payment processing.
Relevant individuals should refer to the Company’s privacy notice for more information on the reasons for its processing activities, the lawful bases it relies on for the processing and data retention periods.

 

Data Protection Principles

All personal data obtained and held by the Company will:

  • be processed fairly, lawfully and in a transparent manner
  • be collected for specific, explicit, and legitimate purposes
  • be adequate, relevant and limited to what is necessary for the purposes of processing
  • be kept accurate and up to date. Every reasonable effort will be made to ensure that inaccurate data is rectified or erased without delay
  • not be kept for longer than is necessary for its given purpose
  • be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  • comply with the relevant applicable data protection laws and procedures for international transferring of personal data.

 

Data Subject Rights

In addition, personal data will be processed in recognition of an individuals data protection rights, as may be enshrined under various data protection law and regulations which the company may be subject to.
The company makes a commitment to honour rights that a data subject may enjoy under any applicable data protection law.
Some of the rights available to the data subjects are:

  • the right to be informed
  • the right of access
  • the right for any inaccuracies to be corrected (rectification)
  • the right to have information deleted (erasure)
  • the right to restrict the processing of the data
  • the right to portability
  • the right to object to the inclusion of any information
  • the right to regulate any automated decision-making and profiling of personal data.

Exercise and processing of these rights shall be subject to the applicable data protection laws and regulation governing these rights.

 

Processing of Personal Data

All processing of personal data must meet one of the following bases:

  • Where we have the consent of the data subject
  • Where it is in our legitimate interests and this is not overridden by the rights and freedoms of the data subject.
  • Where necessary to meet a legal obligation.
  • Where necessary to fulfil a contract, or pre-contractual obligation.
  • Where we are protecting someone’s vital interests.
  • Where we are fulfilling a public task or acting under official authority.

Any special category data /sensitive types of personal data as defined must further be processed only in the line with one of the conditions specified in the relevant laws.
The most appropriate lawful basis will be noted in the Data Processing Register.
Where processing is based on consent, the data subject has the option to easily withdraw their consent.
Where electronic direct marketing communications are being sent, the recipient should have the option to opt-out in each communication sent, and this choice should be recognised and adhered to by us.
Personal data must be processed in a lawful manner and in good faith. Data Processing may only take place if and insofar as a sufficient legal basis exists for the processing activity. Only such data would be processed, which would be necessary. Such personal data would be updated regularly. Personal data must be processed in a manner that uses technical or organisational measures to ensure appropriate security that protects the data against unauthorised or unlawful processing and against accidental loss, destruction or damage.

 

Procedures

The Company has taken the following steps to protect the personal data of relevant stakeholders, which it holds or to which it has access:
• it appoints or employs employees with specific responsibilities for:
o the processing and controlling of data
o the comprehensive reviewing and auditing of its data protection systems and procedures o overviewing the effectiveness and integrity of all the data that must be protected.

  • There are clear lines of responsibility and accountability for these different roles.
  • it provides information to its stakeholders on their data protection rights, how it uses their personal data, and how it protects it. The information includes the actions relevant individuals can take if they think that their data has been compromised in any way
  • it provides its employees with information and training to make them aware of the importance of protecting personal data, to teach them how to do this, and to understand how to treat information confidentially
  • it can account for all personal data it holds, where it comes from, who it is shared with and also who it might be shared with
  • it carries out risk assessments as part of its reviewing activities to identify any vulnerabilities in its personal data handling and processing, and to take measures to reduce the risks of mishandling and potential breaches of data security. The procedure includes an assessment of the impact of both use and potential misuse of personal data in and by the Company
  • it recognises the importance of seeking individuals’ consent for obtaining, recording, using, sharing, storing and retaining their personal data, and regularly
    reviews its procedures for doing so, including the audit trails that are needed and are followed for all consent decisions. The Company understands that consent must be freely given, specific, informed and unambiguous. The Company will seek consent on a specific and individual basis where appropriate. Full information will be given regarding the activities about which consent is sought. Relevant individuals have the absolute and unimpeded right to withdraw that consent at any time
  • it has the appropriate mechanisms for detecting, reporting and investigating suspected or actual personal data breaches, including security breaches. It is aware of its duty to report significant breaches that cause significant harm to the affected individuals to the relevant supervisory authority, and is aware of the possible consequences
  • it is aware of the implications of international transfer of personal data internationally.

 

Access to Data

Relevant individuals have a right to be informed whether the Company processes personal data relating to them and to access the data that the Company holds about them. Requests for access to this data will be dealt with under the following summary guidelines:

  • a form on which to make a subject access request is available. The request should be made to support@spoclog.com
  • the Company will not charge for the supply of data unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request
  • the Company will respond to a request without delay. Access to data will be provided, subject to legally permitted exemptions, within one month as a maximum. This may be extended by a further two months where requests are complex or numerous.
    Relevant individuals must inform the Company immediately if they believe that the data is inaccurate, either as a result of a subject access request or otherwise.
    The Company will take immediate steps to rectify the information.
    For more information on making a subject access request, reach out to our Data Protection Officer at support@spoclog.com

 

Data Disclosures

The Company may be required to disclose certain data/information to any of the following:

  • regulatory authorities and enforcement agencies
  • any court of law or any relevant party in connection with any claim or legal proceedings
  • our contractors, service providers, consultants, auditors and advisors on a need to know basis. The Personal Information may in some circumstances be transferred overseas however we will also ensure that these overseas entities we work with observe strict confidentiality and data protection obligations.
    The responsible department must inform the data subjects of the purposes and circumstances of the processing of their personal data in a concise, transparent, intelligible and easily accessible form and in clear and plain language. This information must be given whenever the personal data is collected for the first time. If the Company receives the personal data from a third party, it must provide the information to the data subject within a reasonable period after obtaining the data, unless
  • the data subject already has the information or
  • it would be impossible or
  • extremely difficult to provide this information.

These kinds of disclosures will only be made when strictly necessary for the purpose.

 

Data Security

With constant developments and changes in technology and innovations facilitating data sharing and access, it is important that a consistent approach be adopted to safeguard personal data.
SpocLog will ensure that appropriate technical and organizational measures are in place, supported by privacy impact and risk assessments, to ensure a high level of security for personal data, and secure environment for information held both manually and electronically.
The Company adopts procedures designed to maintain the security of data when it is stored and transported.
In addition, as part of its organizational security measures, employees at SpocLog must:

  • ensure that all files or written information of a confidential nature are stored in a secure manner and are only accessed by people who have a need and a right to access them
  • ensure that all files or written information of a confidential nature are not left where they can be read by unauthorised people
  • check regularly on the accuracy of data being entered into computers
  • always use the passwords provided to access the computer system cautiously and such access should not be circulated, unless absolutely necessary
  • use computer screen blanking to ensure that personal data is not left on screen when not in use.
    Personal data should not be kept or transported on laptops, USB sticks, or similar devices, unless authorised. Where personal data is recorded on any such device it should be protected by:
  • ensuring that data is recorded on such devices only where absolutely necessary
  • using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted
  • ensuring that laptops or USB drives are not left lying around where they can be stolen.

Failure to follow the Company’s rules on data security may be dealt with via the Company’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.

 

International Data Transfers

The Company may be required to transfer personal data to a country/ countries outside of the respective jurisdiction.
Transmission of personal data to recipients outside or inside the Company is subject to the authorization requirements for processing personal data.
The data recipient must be required to use the data only for defined purposes.
In the event of a cross-border transmission of personal data (including granting access from another country), the relevant national requirements for the transfer of personal data abroad must be fulfilled. Personal data from the EU may only be processed outside the Companies in a third country if the recipient can prove that it has a data protection level equivalent to this Policy.
Transfers of personal data to any public authority cannot be massive, disproportionate and indiscriminate in a manner that would go beyond what is necessary in a democratic society. In the event of conflicts between these and public authority requirements, the company will find a practical solution that fulfils the purpose of this Policy.

 

Breach Notification

Where a data breach is likely to result in a risk to the rights and freedoms of individuals, it will be reported to the relevant supervisory authority within 72 hours of the Company becoming aware of it and may be reported in more than one instalment.
Individuals will be informed directly in the event that the breach is likely to result in a high risk to the rights and freedoms of that individual.
If the breach is sufficient to warrant notification to the public, the Company will do so without undue delay.

 

Training

New employees must read and understand the policies on data protection as part of their induction.
All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.
The nominated data controller/auditors/protection officers for the Company are trained appropriately in their roles under the applicable laws.
All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.

 

Record

Records management refers to a set of activities required for systematically controlling the creation, distribution, use, maintenance, and disposition of recorded information maintained as evidence of business activities and transactions. It is impossible to be compliant with information law without robust records management policies and practises.
The Company keeps records of its processing activities including the purpose for the processing and retention periods in its Data Retention Records. These records will be kept up to date so that they reflect current processing activities.
Good records management practices ensure not only record quality, but that personal data is only kept for as long as necessary for its original purpose and help support data minimization.
SpocLog is committed to implementing robust management policy, process, and practises to ensure compliance with the applicable data protection laws and regulations.

 

Organization and Responsibilities

SpocLog will maintain records of data processing as required under and in accordance with relevant data protection laws, the company may be subject to.
The ‘Data Protection Officer’ (DPO) has the specific responsibility of overseeing data protection and ensuring that we comply with the data protection principles and relevant legislation.
The DPO will ensure that the Data Processing Register is kept up to date and demonstrates how the data protection principles are adhered to by our activities.
Individual members of staff have a duty to contribute to ensure that the measures outlined in the Register are accurately reflected in our practice.
Our compliance with relevant policies and regulatory requirements in respect of data protection as part of our Data Management Strategy will be periodically monitored internally by a designated governance group.
All employees, volunteers, consultants, partners or other parties who will be handling personal data on behalf of SpocLog will be appropriately trained and supervised where necessary.
The collection, storage, use and sharing of personal data will be regularly reviewed by the Data Protection Officer, the Governance Group, and any relevant business area.
We will adhere to relevant codes of conduct where they have been identified and discussed as appropriate.
Where there is likely to be a high risk to individuals rights and freedoms due to a processing activity, we will first undertake a Data Protection Impact Assessment (DPIA) and consult with the relevant supervisory authority prior to processing if necessary.

 

Conflicts of Law

This Policy is intended to comply with the laws and regulations in the place of establishment and of the countries in which company operates. In the event of any conflict between this Policy and applicable laws and regulations, the latter shall prevail.