Data Protection

Introduction

Umbrella Digital Ltd is registered under the Data Protection Act with the Information Commissioners Office under registration number ZB191408

Umbrella Digital 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 information may be used by the Company to:

• record details of entrants to promotional offers and competitions
• select winners and maintain winners' lists for promotional competitions
• provide marketing, advertising and public relation services to our clients
• maintain our accounts and records
• promote our services
• undertake research
• support and manage our employees

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 that Umbrella Digital:

• Complies with data protection law and follows good practice
• Protects the rights of staff, customers and business 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 and General Data Protection Regulation describes how organisations — including Umbrella Digital 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:

1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

Policy scope

This policy applies to:

• All staff and contractors working for Umbrella Digital
• All suppliers and other people working on behalf of Umbrella Digital
• 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
  • Any other information relating to individuals

General Data Protection Regulations (GDPR in effect from May 2018)

The introduction of new data protection regulations means that Umbrella Digital Ltd will advise on marketing campaigns ensuring that consumer data is considered at all times. Umbrella Digital Ltd advice will include:

• Consideration to breaches of confidentiality. For instance, information being given out inappropriately by those working on the campaign.
• Offering choice. For instance, all individuals should be free to choose how the advertising company uses data relating to them.
• Privacy by design – all work carried out must first consider the right of privacy by consumers.
• Consent – keep a record of when and where consumers consent was received.
• Personal Data – data must be encrypted at rest and during transit.
• Maintaining robust records – a single consumer can be tracked across any campaign.
• Right to be forgotten – personal information can be deleted at any time across all departments and all databases.

Responsibilities

Everyone who works for or with Umbrella Digital Ltdhas 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 Umbrella Digital Ltd meets its legal obligations.

The Data Protection Officer, (Elizabeth Johnson) is responsible for:

• 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.

The Director (Nick Carter) 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 Director (Elizabeth Johnson) 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.
• The Company 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 Data Protection Officer 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 and never shared between employees. See Password Policy.
• Ensure the password is strong enough – entropy.
• Data should only be stored on approved servers and should only be uploaded to an approved cloud storage.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently to both hard storage and automatically to cloud storage. The backups should have an alarm system in place in case of failure.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones. Removable storage devices are not permitted and should never be used.
• All servers and computers containing data should be protected by approved security software and a firewall.