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      Data Protection Policy

      This is our latest data protection policy

      Introduction

      Purpose

      The purpose of this policy is to explain our approach to ensuring that we comply with the General Data Protection Regulation (GDPR) when we collect, process and store the personal data that we need to carry out our business. This policy forms part of Expansive’s overall information security management system (ISMS)

      Expansive Solutions (Expansive) 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 standards, and to comply with the “UK GDPR” law. It places strict obligations on how organisations handle personal data.

      Context and Scope

      This Policy applies to all Expansive users including third parties and contractors with access to Expansive information (including customer information) or IT systems.

      Document Owner

      The ultimate owner of this document is Expansive’s Management Review Board (MRB).

      The executive sponsor for this policy is the CEO

      The operational custodian of this policy is the CTO.

      Why this policy exists

      The Data Protection Policy ensures Expansive:

      • Complies with applicable data protection laws and follow good practice 

      • Protects the rights of staff, customers and partners

      • Remains transparent about how it stores and processes individuals’ data

      • Protects itself from the risks of a data breach

      The General Data Protection Regulation (GDPR)

      The GDPR describes how organisations 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 GDPR is underpinned by seven important principles. These principles lie at the heart of our approach to processing personal data.

      • Lawfulness, fairness and transparency

      • Purpose limitation

      • Data minimisation

      • Accuracy

      • Storage limitation

      • Integrity and confidentiality (security)

      • Accountability

      People

      This policy applies to:

      • All staff and volunteers of Expansive

      • All contractors, suppliers and other people working on behalf of Expansive.

      Data

      This policy applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of GDPR. This can include:

      • Names of individuals

      • Postal addresses

      • Email addresses

      • Telephone numbers

      • Any information capable of identifying individuals

      Risks

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

      • Breaches of confidentiality. For instance, information 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.

      Responsibilities

      Everyone who works for or with Expansive 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 GDPR principles. 

      However, the following have key areas of responsibility:

      • The board of directors is ultimately responsible for ensuring that Expansive meets its legal obligations.

      • The Management Review Board is responsible for ensuring Expansive’s ISMS is properly maintained and implemented which includes:

        • Keeping the board of directors 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

        • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data

      • The CTO is responsible for handling requests from individuals to see the data Expansive holds about them (i.e. subject access requests)

      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.

      • Expansive 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 unauthorised 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 CTO if they are unsure about any aspect of data protection. 

      Data Storage

      These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the CTO.

      When data is stored on paper (hard copy)

      • it should be kept in a secure place where unauthorised people cannot see it, e.g. in a locked drawer, filing cabinet or other secure location

      • it should not be left where unauthorised people could see them, e.g. on a printer

      • data should be shredded and disposed of securely when no longer required

      When data is stored electronically

      • it must be protected from unauthorised access, accidental deletion and malicious hacking attempts using controls outlined in Expansive’s ISMS. In particular:

        • 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 an approved cloud computing service.

        • 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.

      Data Use

      Personal data is of no value to Expansive 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.

      • Data must be encrypted before being transferred electronically. The CTO can explain how to send data to authorised external contacts.

      • Personal data should never be transferred outside 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.

      Data Accuracy

      The law requires Expansive 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 Expansive 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.

      • Expansive will make it easy for data subjects to update the information Expansive 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 COO’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

      Subject Access Requests

      All individuals who are the subject of personal data held by Expansive are entitled to:

      • Ask what information the company holds 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, this is called a subject access request (SAR).

      SARs from individuals should be made by email, addressed to the data controller at data@expansive.co.uk. The data controller can supply a standard request form, although individuals do not have to use this.

      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, UK law allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

      Under these circumstances, Expansive 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

      Expansive 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.