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Nov 2019 |
Issued for review and approval |
SJS |
JB |
SJS |
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Document Amendment History |
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The copy holder is responsible for the removal and destruction of superseded page(s) from this document, replacing them with revised page(s) issued and signed as holder of this record amendment sheet |
Company |
means Dataverse-AIM Ltd, a registered Company in England & Wales |
GDPR |
means the General Data Protection Regulation. |
Responsible Person |
means Stephen Searle |
Register of Systems |
means a register of all systems or contexts in which personal data is processed by the Company. |
The
Company
is committed to processing data in accordance with its
responsibilities under the GDPR.
Article
5 of the GDPR requires that personal data shall be:
a. processed
lawfully, fairly and in a transparent manner in relation to
individuals;
b. collected
for specified, explicit and legitimate purposes and not further
processed in a manner that is incompatible with those purposes;
further processing for archiving purposes in the public interest,
scientific or historical research purposes or statistical purposes
shall not be considered to be incompatible with the initial
purposes;
c. adequate,
relevant and limited to what is necessary in relation to the purposes
for which they are processed;
d. accurate
and, where necessary, kept up to date; every reasonable step must be
taken to ensure that personal data that are inaccurate, having regard
to the purposes for which they are processed, are erased or rectified
without delay;
e. kept
in a form which permits identification of data subjects for no longer
than is necessary for the purposes for which the personal data are
processed; personal data may be stored for longer periods insofar as
the personal data will be processed solely for archiving purposes in
the public interest, scientific or historical research purposes or
statistical purposes subject to implementation of the appropriate
technical and organisational
measures required by the GDPR in order to safeguard the rights and
freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures”.
a. To
ensure its processing of data is lawful, fair and transparent, the
Company
shall maintain a Register of Systems.
b. The
Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.
a. All
data processed by the Company must be done on one of the following
lawful bases: consent, contract, legal obligation, vital interests,
public task or legitimate interests.
(see
ICO guidance for more information)
b. The
Company shall note the appropriate lawful basis in the Register of
Systems.
c. Where
consent is relied upon as a lawful basis for processing data,
evidence of opt-in consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.
a. The
Company shall ensure that personal data are adequate, relevant and
limited to what is necessary in relation to the purposes for which
they are processed.
a. The
Company shall take reasonable steps to ensure personal data is
accurate.
b. Where
necessary for the lawful basis on which data is processed, steps
shall be put in place to ensure that personal data is kept up to
date.
a. To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.
a. The
Company shall ensure that personal data is stored securely using
modern software that is kept-up-to-date.
b. Access
to personal data shall be limited to personnel who need access and
appropriate security should be in place to avoid unauthorised sharing
of information.
c. When
personal data is deleted this should be done safely such that the
data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
END OF POLICY
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S. J. Searle CEng FIET Director |
J.
G. Burns |
Rev1 |
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1st November 2019 |