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Data Privacy Policy

Introduction

Orion Security Print Limited (OSP) 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 and standards – and to comply with the law.

Why this policy exists

This data protection policy ensures OSP:

• 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 risk of a data breach

Data protection law

The General Data Protection Regulation (GDPR) 2018, describes how organisations – including Orion Security Print Limited – 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 General Data Protection Regulation (GDPR) 2018 is underpinned by the following important principles. These say that personal data must:

1. Be processed fairly and lawfully.
2. Be obtained only for specific, lawful purposes.
3. Be adequate, relevant and not excessive, be accurate and kept up to date.
4. Not be held for longer than necessary.
5. Processed in accordance with the rights of data subjects.
6. Be protected in appropriate ways.
7. Be transmitted in accordance with the GDPR.
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.

People, risks and responsibilities Policy scope

This policy applies to:

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

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of The General Data Protection Regulation (GDPR) 2018. This can include:

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

Data protection risks

This policy helps to protect OSP from some very real data security risks, including:

• Breaches of confidentially. For instance, information being given out inappropriately.
Failing to offer choice. For instance, all individuals will be free to choose how the company uses data relating to them.
Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Sales and Marketing

OSP will occasionally run sales and marketing campaigns. Under GDPR requirements, OSP will ensure consent is obtained prior to distributing any sales and marketing communication.

Responsibilities

Everyone who works for or with OSP 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 OSP meets its legal obligations.

The Fulfilment Director, Ian Earley, is responsible for:

• Keeping the board updated about GDPR responsibilities, risk and issues.
• Reviewing all GDPR procedures and related policies, in line with an agreed schedule.
• Arranging GDPR training and advice for the people covered by this policy.
• Handling GDPR questions from staff and anyone else covered by this policy.
• Dealing with requests from individuals to see the data OSP holds about them (also called ‘subject access requests’).
• Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

The infrastructure Manager, James Oliver, is responsible for:

• Ensuring all systems, services and equipment used for storing data meets acceptable security standards.
• Performing regular checks and scans to ensure security hardware and software is functioning properly.
• Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

The Fulfilment Director, Ian Earley, is responsible for:

• Approving any GDPR statements attached to communications such as email and letters.
• Addressing any GDPR queries from journalists or media outlets like newspapers.
• Where necessary, working with other staff to ensure marketing initiatives abide by GDPR principles.

OSP staff guidelines

• The only people able to access data covered by this policy will be 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.
OSP will provide training to all employees to help them understand their responsibilities when handling data.
• Employees will keep all data secure by taking sensible precautions and following the guidelines below.
• In particular, strong passwords must be used and they will never be shared.
• Personal data will not be disclosed to unauthorised people, either within the company or externally.
• Data will be regularly reviewed and updated if it is found to be out of date, no longer relevant or If no longer required, it will be deleted and disposed of.
• Employees will request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data Storage

These rules describe how and where data will 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 will 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 will be kept in a locked drawer or filing cabinet.
• Employees will make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
Data printouts will be shredded and disposed of securely when no longer required.

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

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

Data use

Personal data is of no value to OSP 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 will ensure the screens of their computers are always locked when left unattended.
• Personal data will not be shared informally. In particular, it will never be sent by email, as this form of communication is not secure.
• Data will be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
• Personal data will never be transferred outside of the European Economic Area.
• Employees will not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy

The law requires OSP to take reasonable steps to ensure data is kept accurate and up to date
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
• Data will be held in as few places as necessary. Staff will not create any unnecessary additional data sets.
• Staff will take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• OSP will make it easy for data subjects to update the information OSP holds about them, For instance, via the company website.
• Data will be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it will be removed from the database.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files.

Subject access requests

All individuals who are the subject of personal data held by OSP are entitled to:
• Ask what information the company holds about them and why.
• Ask how to gain access to it.
• Ask to correct your data
• Ask for it to be deleted.
• Be informed how to keep it up to date.
• Be informed how the company is meeting its data protection obligations.
Object to the processing of it.

If an individual contacts the company requesting this information, and you wish to exercise any of the rights set out above, please email us at fulfilment@orionprint.com

Subject access requests from individuals will be made by email, addressed to the data controller at {email address}. The data controller can supply a standard request form, although individuals do not have to use this.

Under normal circumstances access to individuals data is free; however, a fee may be charged for excessive or repetitive requests. 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 General Data Protection Regulation (GDPR) 2018 allows personal data to be disclosed to enforcement agencies without the consent of the data subject.

Under these circumstances, OSP 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.

Providing information

OSP aims to ensure that individuals are aware that their data is being processed and that they understand:

• How the data is being used
• How to exercise their rights


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