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+1 201-331-3136 adam.klinger@dakithub.com

General Data Protection Policy:

CONTEXT AND OVERVIEW
Key details
 Policy prepared by: DAK IT
 Approved by board / management on: 18/03/2018
 Policy became operational on: 01/04/2018
 Next review date: 01/09/2018

Introduction

DAK IT needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other
people the organization 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 law.

Why this policy exists

This data protection policy ensures DAK IT:
 Complies with data protection law and follow 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

Data protection law

The Data Protection Act 1998 describes how organizations — including DAK IT— 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 Data Protection Act is underpinned by eight important principles. These say that personal
data Be processed fairly and lawfully must:
1. Be obtained only for specific, lawful purposes
2. Be adequate, relevant and not excessive
3. Be accurate and kept up to date
4. Not be held for any longer than necessary
5. Processed in accordance with the rights of data subjects
6. Be protected in appropriate ways
7. Not be transferred outside the European Economic Area (EEA), unless that
country or territory also ensures an adequate level of protection

PEOPLE, RISKS AND RESPONSIBILITIES

Policy scope

This policy applies to:
 The head office of DAK IT
 All branches of DAK IT
 All staff and volunteers of DAK IT
 All contractors, suppliers and other people working on behalf of DAK IT
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
 …plus any other information relating to individuals

Data protection risks
This policy helps to protect DAK IT 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 DAK IT 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 data protection principles.
However, these people have key areas of responsibility:
 The board of directors is ultimately responsible for ensuring that DAK IT meets its
legal obligations.
 The data protection officer is responsible for:
o Keeping the board updated about data protection responsibilities, risks and issues.
o Reviewing all data protection procedures and related policies, in line with an agreed
schedule.
o Arranging data protection training and advice for the people covered by this policy.
o Handling data protection questions from staff and anyone else covered by this
policy.
o Dealing with requests from individuals to see the data DAK IT holds
about them (also called ‘subject access requests’).
o Checking and approving any contracts or agreements with third parties that
may
handle the company’s sensitive data.
 The IT manager is responsible for:
o Ensuring all systems, services and equipment used for storing data meet acceptable
security standards.
o Performing regular checks and scans to ensure security hardware and software is
functioning properly.
o Evaluating any third-party services the company is considering using to
store or process data. For instance, cloud computing services.
 The marketing manager is responsible for:
o Approving any data protection statements attached to communications such as
emails and letters.
o Addressing any data protection queries from journalists or media outlets like
newspapers.
o Where necessary, working with other staff to ensure marketing initiatives abide
by data protection principles.

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.
 DAK IT 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.

DATA STORAGE
These rules describe how and where data should be safely stored. Questions about storing data
safely can be directed to the IT manager or data controller.
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 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 an 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
smart phones.
 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 DAK IT 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 IT manager can
explain how to send data to authorized external contacts.
 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.

DATA ACCURACY
The law requires DAK IT 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 DAK IT 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.
 DAK IT will make it easy for data subjects to update the information
DAK IT 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 who are the subject of personal data held by DAK IT 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.
Subject access requests from individuals should be made by email, addressed to the data
controller at dpo@dakithub.com , 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, the Data Protection Act allows personal data to be disclosed to
law enforcement agencies without the consent of the data subject.
Under these circumstances, DAK IT 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
DAK IT 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.

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