DATA PROTECTION POLICY

You can find the Data Protection Addendum (DPA) here: okmusician.com/dpa

Context and overview

Key details

Policy prepared by: Head of Product
Approved by board / management on: 06.2019
Policy became operational on: 06.2019
Next review date: June 2020

Introduction

OKMatrix Ltd 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 law.

Why this policy exists

This data protection policy ensures OKMatrix Ltd:

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 organisations — including OKMatrix Ltd — 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 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
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 OKMatrix Ltd
All branches of OKMatrix Ltd
All staff and volunteers of OKMatrix Ltd
All contractors, suppliers and other people working on behalf of OKMatrix Ltd

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 OKMatrix Ltd 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 OKMatrix Ltd 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 OKMatrix Ltd meets its legal obligations.
The IT manager is responsible for:
- 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 is functioning properly.
- Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
The Chief Marketing Officer is responsible for:
- Approving any data protection statements attached to communications such as emails and letters.
- Addressing any data protection queries from journalists or media outlets like newspapers.
- 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.
OKMatrix 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 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 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 unauthorised 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 unauthorised 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 unauthorised 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 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 OKMatrix 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.
Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised 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 OKMatrix 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 OKMatrix 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.
OKMatrix Ltd will make it easy for data subjects to update the informationOKMatrix 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 who are the subject of personal data held by OKMatrix Ltd 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 service(at)okmusician.com. The data controller can supply a standard request form, although individuals do not have to use this.
Individuals will be charged 10€ per subject access request. 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, OKMatrix Ltd 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

OKMatrix Ltd 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. This is available on request. A version of this statement is also available on the company's website.