Data Protection and Records Management Policy
GENERAL DATA PROTECTION REGULATIONS (DATE APPROVED: 9.03.23) STATEMENT FOR CLIENTS
- Values Statement
Self Space prides itself on openness and transparency in all we do and the way we gather, process, store, transfer and dispose of data is no exception.
This policy will detail our roles in data management, how we meet our obligations, our expectations of those working with/for us and the actions to be taken should either our standards and/or any legal framework is broken.
This policy supports the following company values:
- We keep clients at the heart of what we do
- We say what needs to be said and
- We take responsibility
- Policy brief & purpose
This Self Space Policy details our commitment to treat information of employees, customers, stakeholders and other interested parties with the utmost care and confidentiality.
With this policy, we ensure that we gather, store and handle data fairly, transparently and with respect towards individual rights.
This policy refers to all parties (employees, job candidates, customers, suppliers etc.) who provide any amount of information to us.
2.2 Who is covered under the Data Protection Policy?
Employees of our company and its subsidiaries must follow this policy. Contractors, consultants, partners and any other external entity are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf and may need occasional access to data.
- Policy elements
As part of our operations, we need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, usernames and passwords, digital footprints, photographs, social security numbers, financial data etc.
Our company collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply.
Our data will be:
- Accurate and kept up-to-date
We recognise the need to retain a certain amount of data in order to perform our core business and to maintain our working practices and that the data must be up to date and accurate.
Data will be reviewed for relevance and accuracy on each occasion where the data provider re-commissions our work or there is a contractual obligation to re-engage with the data provider. Any amendments will be updated across our platforms accordingly.
Collected fairly and for lawful purposes only
Personal data is any information relating to an identified or identifiable individual. It does not include data where the identity has been removed (i.e. anonymous data). We may collect, use, store and transfer different kinds of personal data about you when we engage with you.
This may include:
- Identity Data – title, first name, last name, date of birth or similar identifiers. If you interact with us through social media, this may include your social media username;
- Contact Data – billing address, email address and telephone numbers;
- Financial Data – bank account and payment card details;
- Transaction Data – details about services we have provided to you;
- Technical Data – includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the website;
- Profile Data – your username and password, your preferences, feedback and
- survey responses;
- Geographical Data – information setting out your primary address to control the
- use of location services in most mobile devices and desktop settings;
- Usage Data – information about how you use our website and services;
- Marketing and Communications Data – includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Processed by the company within its legal and moral boundaries
UK data protection law requires us to have a “legal basis” for processing personal data. The legal bases we rely on are:
- Performance of a contract we are about to enter into or have entered into with you;
- Compliance with a legal or regulatory obligation;
- Carrying out activities that are legitimate to our business interests;
However, generally, we shall not rely on consent as a legal basis for processing personal data other than where the law requires it. Where our legal basis is consent, data providers have the right to withdraw consent any time.
Protected against any unauthorized or illegal access by internal or external parties
All Self Space data sources are secured on platforms that are password protected and all those with access to data have enhanced DBS clearances in place.
Our data will not be:
- Communicated informally
- Stored for more than a specified amount of time
- Self Space will weed any data from systems after the reason for the collection has expired and after 10 years in all other cases.
- Transferred to organizations, states or countries that do not have adequate data protection policies
- Distributed to any party other than the ones agreed upon by the data’s owner (exempting legitimate requests from law enforcement authorities)
In addition to ways of handling the data the company has direct obligations towards people to whom the data belongs. Specifically we must:
- Let people know which of their data is collected
- Inform people about how we’ll process their data
- Inform people about who has access to their information
- Have provisions in cases of lost, corrupted or compromised data
- Allow people to request that we modify, erase, reduce or correct data contained in our databases
To exercise data protection we’re committed to:
- Restrict and monitor access to sensitive data
- Develop transparent data collection procedures
- Train employees in online privacy and security measures
- Build secure networks to protect online data from cyberattacks
- Establish clear procedures for reporting privacy breaches or data misuse
- Include contract clauses or communicate statements on how we handle data
- Establish data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorization etc.)
- Disciplinary Consequences
All principles described in this policy must be strictly followed. A breach of data protection guidelines will invoke disciplinary and possibly legal action.