Data protection policy – Context and overview
- Policy prepared by: SeeResponse Technologies Pvt. Ltd.
- The policy became operational on May 10, 2019
- Next review date: May 10, 2022
SeeResponse Technologies Pvt. Ltd needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees, and other people with whom the organization has a relationship 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 standards — and to comply with the law.
Why this policy exists
This data protection policy ensures SeeResponse Technologies Pvt. Ltd.:
- 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
These rules apply regardless of whether data is stored electronically, on paper, or in other materials.
Personal information must be collected and used fairly, stored safely, and not disclosed unlawfully to comply with the law.
Eight important principles underpin our policy. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant, and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
People, risks, and responsibilities
This policy applies to:
- All offices of SeeResponse Technologies Pvt. Ltd.
- All staff and volunteers of SeeResponse Technologies Pvt. Ltd.
- All contractors, suppliers, and other people working on behalf of SeeResponse Technologies Pvt. Ltd.
- It applies to all data that the company holds relating to identifiable individuals. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Any other information relating to individuals
Data protection risks
This policy helps to protect SeeResponse Technologies Pvt. Ltd from some genuine data security risks, including:
- Breaches of confidentiality. For instance, information is being given out inappropriately.
- Failing to offer choice. For instance, all individuals should 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.
Everyone who works for or with SeeResponse Technologies Pvt. Ltd is responsible for ensuring data is collected, stored, and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed according to this policy and data protection principles.
- Keeping the board updated about data protection responsibilities, risks, and issues.
- Reviewing all data protection procedures and related policies in line with an agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data [company name] 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.
- Ensuring all systems, services, and equipment used for storing data meet acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software functions correctly.
- Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
General staff guidelines
- The only people able to access data covered by this policy should be those who need it for their work.
- Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
- SeeResponse Technologies Pvt. Ltd will provide training to all employees to help them understand their responsibilities when handling data.
- Employees should keep all data secure by taking sensible precautions and following the guidelines below.
- In particular, strong passwords must be used, and they should never be shared.
- Personal data should not be disclosed to unauthorized people, either within the company or externally.
- Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
- Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored.
When data is stored on paper, it should be kept secure 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 drawer or filing cabinet.
- Employees should make sure paper and printouts are not left where unauthorized people could see them, like on a printer.
- 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 (like a CD or DVD), these should be kept locked away securely when not being used.
- Data should only be stored on designated drives and servers, and should only be uploaded to approved cloud computing services.
- Servers containing personal data should be sited in a secure location, away from general office space.
- Data should be backed up frequently. Those 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 like tablets or smartphones.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to SeeResponse Technologies Pvt. Ltd 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 always locked when left 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.
- 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 SeeResponse Technologies Pvt. Ltd 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 SeeResponse Technologies Pvt. Ltd should put into ensuring its accuracy.
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 should not create any unnecessary additional data sets.
- Staff should take every opportunity to ensure data is updated, for instance, by confirming a customer’s details when they call.
- SeeResponse Technologies Pvt. Ltd will make it easy for data subjects to update the information SeeResponse Technologies Pvt. Ltd 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.
- It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject access requests
All individuals are the subject of personal data held by SeeResponse Technologies Pvt. Ltd is entitled to:
- Ask what information the company holds about them and why.
- Ask how to gain access to it.
- Be informed on 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, this is called a subject access request.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
SeeResponse Technologies Pvt. Ltd aims to ensure that individuals are aware that their data is being processed and that they understand.
To these ends, the company has a privacy statement setting out how the company uses data relating to individuals.