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General Data Protection Policy

Introduction

ITcost is committed to protecting the rights and freedoms of data subjects, and safely and securely processing their data in accordance with all of our legal obligations.

We hold personal data about our employees, clients, suppliers and other individuals for a variety of business purposes.

This policy sets out how we seek to protect personal data and ensure compliance with the General Data Protection Regulation.

‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Special categories of data include information about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings, and genetic and biometric information —any use of special categories of personal data should be strictly controlled in accordance with this policy.

‘Data controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law.

‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

‘Processing’ means 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, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“We”, “Us” and “Our” refer to ITcost.

The Principles

ITcost shall comply with the principles of data protection (“the Principles”) enumerated in the EU General Data Protection Regulation (“GDPR”). We will make every effort possible in everything we do to comply with these principles. The Principles are:

1. Lawful, fair and transparent

Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.

2. Limited for its purpose

Data can only be collected for a specific purpose.

3. Data minimisation

Any data collected must be necessary and not excessive for its purpose.

4. Accurate

The data we hold must be accurate and kept up to date.

5. Retention

We cannot store data longer than necessary.

6. Integrity and confidentiality

The data we hold must be kept safe and secure.

Accountability and Transparency

Itcost ensures accountability and transparency in all our use of personal data.

Our Procedures

Fair and lawful processing

We must process personal data fairly and lawfully in accordance with individuals’ rights under the first Principle. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.

Lawful basis for processing data

All data processed by ITcost has a lawful basis approved by our DPO. Tcost ensures that at least one of the following conditions applies whenever we process personal data:

  • Consent
    We hold recent, clear, explicit, and defined consent for the individual’s data to be processed for a specific purpose.
  • Contract
    The processing is necessary to fulfil or prepare a contract for the individual.
  • Legal obligation
    We have a legal obligation to process the data (excluding a contract).
  • Vital interests
    Processing the data is necessary to protect a person’s life or in a medical situation.
  • Public function
    Processing necessary to carry out a public function, a task of public interest or the function has a clear basis in law.
  • Legitimate interest
    The processing is necessary for our legitimate interests. This condition does not apply if there is a good reason to protect the individual’s personal data which overrides the legitimate interest.

Special Categories of Personal Data

What are special categories of personal data?

Previously known as sensitive personal data, this refers to data about an individual that is more sensitive, and therefore requires more protection. This type of data could create more significant risks to a person’s fundamental rights and freedoms, for example by putting them at risk of unlawful discrimination. The special categories include information about an individual’s:

  • race
  • ethnic origin
  • politics
  • religion
  • trade union membership
  • genetics
  • biometrics (where used for ID purposes)
  • health
  • sexual orientation

Itcost does not process any special category personal data.

Responsibilities

Below we have listed ITcost responsibilities that ensure data is appropriately controlled and processed.

ITcost responsibilities:

  • Analysing and documenting the type of personal data we hold
  • Checking procedures to ensure they cover all the rights of the individual
  • Identifying the lawful basis for processing data
  • Ensuring consent procedures are lawful
  • Implementing and reviewing procedures to detect, report and investigate personal data breaches
  • Storing data in safe and secure ways
  • Assessing the risk that could be posed to individual rights and freedoms should data be compromised

ITcost employee responsibilities:

  • Fully understand data protection obligations
  • Check that any data processing activities that are personally dealt with, comply with our policy and are justified
  • Do not use data in any unlawful way
  • Do not store data incorrectly, be careless with it or otherwise cause us to breach data protection laws and our policies through your actions
  • Comply with this policy and ITcost Internal Data Protection Policy at all times
  • Raise any concerns, notify any breaches or errors, and report anything suspicious or contradictory to this policy or our legal obligations without delay

Responsibilities of the IT Manager:

  • Ensure all systems, services, software and equipment meet acceptable security standards
  • Checking and scanning security hardware and software regularly to ensure it is functioning properly
  • Researching third-party services, such as cloud services the company is considering using to store or process data

Responsibilities of the Marketing Manager:

  • Approving data protection statements attached to emails and other marketing copy
  • Ensuring data protection queries from clients, target audiences or media outlets are addressed appropriately
  • Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy

Accuracy and relevance

We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

Data security

General systems, servers & cloud services:

ITcost ensures all data we hold either on our own systems, servers or on cloud-based software, is as secure as possible against loss or misuse. This entails using two factor authentication, encryption, secure data centres, password managers and security software in addition to staff training.

We also do regular security reviews of all ITcost systems and apply patches for security issues.

Third parties:

ITcost only passes data to third parties as necessary to provide our services, or communications about our services. All third parties have been vetted for adequate security and checked for compliance with the GDPR as part of our security measures review.

Storing data securely

  • ITcost holds little data on paper, and that which is held on paper is secured physically in locked cabinets. Most personal data is held in secure, cloud-based systems that only ITcost authorised staff have access to.
  • Data stored on ITcost computers is protected by strong passwords that are changed regularly.
  • All ITcost cloud-based data storage systems and applications have been approved by the DPO.
  • Data is regularly backed up in line with ITcost backup procedures.

Data retention

We will retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but each case will be determined in a manner consistent with current regulations.

Transferring data internationally

Client data uploaded as part of ITcost Virtual Private Server or Dedicated Server offering is not transferred abroad except to authorised third-party sub-processors as is necessary to fulfil service. In the unusual event that this is necessary, express permission from the DPO would be obtained.