Effective date June 23, 2021
Enstoa 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 privacy notice describes how this personal is collected, handled, and stored to meet the company's data protection standards, and to comply with the law.
Why this policy exists
This data protection policy ensures Enstoa:
- Complies with data protection law and follows 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
This Policy applies to:
- All branches of Enstoa
- All staff of Enstoa
- All contractors, suppliers and other people working on behalf of Enstoa
- 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, and any other personal information relating to individuals)
Data Protection risks
This policy helps to protect Enstoa from data security risks including:
- Breaches of confidentiality - For instance, information being given out inappropriately
- Failing to offer choice - For instance, all individuals should be able to choose how the company uses data relating to them
- Reputational damage - For instance, the company could suffer is hackers successfully gained access to sensitive data
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the data protection officer. When data is stored on paper it should 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 cabinet or drawer
- Employees should make sure paper printouts are not left where unauthorized people could see them
- Data printouts should be shredded and disposed of securely when no longer required
When data is stored electronically, it must be protected from unauthorized access accidental deletion and malicious hacking attempts.
- Data should be protected by strong passwords that are changed regularly and never shared between employees
- If data is stored on removable media (USB) these should be kept locked away securely
- Data should only be stored on designated drives and should only be uploaded to approved cloud computing services
- Data should be backed up frequently. These backups should be tested regularly, in line with the company's standard backup procedures
- Data should never be saved directly to laptops or other mobile devices
- All servers and computers containing data should be protected by approved security software and a firewall
Personal data is of no value to Enstoa 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 should ensure the screens of their computers are locked when unattended
- Personal data should not be shared informally. In particular, it should never be sent by email as this form of communication is not secure
- Data must be encrypted before being transferred electronically
- Personal data should never be transferred outside of the European Economic Area
- Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data
The law requires Enstoa to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort that Enstoa should put into ensuring its accuracy.
It is the responsibility of all employees who work with the data to take reasonable steps to ensure it is kept accurate and as up to date as possible.
- Data will be held in as few places as necessary. Staff should not create any additional data sets
- Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer's details when they call.
- Enstoa will make it easy for data subjects to update the information Enstoa holds about them. For instance, via the company website
- Data should 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
Subject Access Requests
All individuals who are the subject of personal data held by Enstoa are entitled to:
- Ask what information the company hold about them and why
- Ask how to gain access to it
- Be informed how to keep it up to date
- Be informed how the company is meeting its data protection obligations
If an individual contacts the company requesting this information, it is called a subject access request.
Subject access requests from individuals should be made via email, address to the data controller at firstname.lastname@example.org. The data controller can supply a standard request form, although individuals do not have to use this. Individuals will be charged 10 GBP per subject access request. 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 my information.
Disclosing data for any other reasons
In certain circumstances, personal data may be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Enstoa will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the Executives and from the company's legal advisers where necessary.
Enstoa 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
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.