The reasons why this policy exists:
This data protection policy ensures Partnership International, especially with the new regulation enacted on May 25th 2018:
Complies with data protection law and follows good practice
Protects the rights of customers, staff and partners
Is open about how it stores and processed individuals’ data
Protects itself from the risks of data breaches
Data Protection Law:
The General Data Protection Regulation 2106/679 (GDPR for short) describe how organisations – including Partnership International – 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 General Data Protection Regulation is underpinned by 8 important principles. These state that personal date 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 EU, unless that country or territory also ensures an adequate level of protection
People, risks, and responsibilities:
The policy applies to:
The head office of Partnership International located at 19 South Mall, Cork city
All branches of Partnership International.
All staff of Partnership International.
All contractors and people working on behalf of Partnership International.
It applies to all data that the company holds relating to living individual, even if that information technically falls outside of the GDPR. This can include:
Name of individuals
Plus any other information relating directly or indirectly to individuals
Data Protection Risks
This policy helps to protect Partnership International 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.
Who is Responsible?
Everyone who works for or with Partnership International 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.
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 direct manager
Partnership International will provide training to all employees to help them understand their responsibilities with handling data
Employees should keep all data secure, by taking sensible precautions
Personal data should not be disclosed to unauthorised people, either within the company or externally
Data should be reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
These important rules describe how and where data should be safely stored.
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 e.g. in or around the printer.
Data printouts should be shredded and disposed of safely 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 (eg CD/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
Servers containing personal should be sited in a secure location
Data should be backed up frequently. Those back-ups should be tested regularly in line with the company’s standard back up procedures
Data should never be saved directly to laptops or other mobile devices like tables or smart phones
All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no use to Partnership International 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. IT provider 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 the data.
The law requires Partnership International 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 Partnership International 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.
Partnership International will make it easy for data subjects to update the information Partnership International 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 via saved mobile phone 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 6 months.
Subject Access Request
All individuals who are the subject of personal data held by Partnership International 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.
To access your data send a request via email to email@example.com or post to 19 South Mall, Cork city.
Please note proof of identification will also be required to authenticate the request.
Subject access requests from individuals should be made by email, addressed to the data controller at firstname.lastname@example.org.
The data controller can supply a standard request form, although individuals do not have to use this.
Individuals cannot be charged to honour a subject access request. The data controller will aim to provide the relevant data within 30 days.
The data controller will always verify the identity of anyone making a subject access request before handing over information.
Disclosing data for other reasons
In certain circumstance, the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstance, Partnership International will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.
Partnership International 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.
Our privacy is important to Partnershipinternational.ie This privacy statement provides information about the personal information that Partnershipinternational.ie collects, and the ways in which Partnershipinternational.ie uses that personal information.
Personal information collection
Partnershipinternational.ie may collect and use the following kinds of personal information:
[information about your use of this website]
[information that you provide using for the purpose of registering with the website]
[information about transactions carried out over this website]
[information that you provide for the purpose of subscribing to the website services]
[any other information that you send to Partnershipinternational.ie.]
Using personal information
Partnershipinternational.ie may use your personal information to:
[administer this website;]
[personalize the website for you;]
[enable your access to and use of the website services;]
[publish information about you on the website;]
[send to you products that you purchase;]
[supply to you services that you purchase;]
[send to you statements and invoices;]
[collect payments from you;]
[send you marketing communications.]
Where Partnershipinternational.ie discloses your personal information to its agents or sub-contractors for these purposes, the agent or sub-contractor in question will be obligated to use that personal information in accordance with the terms of this privacy statement.
In addition to the disclosures reasonably necessary for the purposes identified elsewhere above, Partnershipinternational.ie may disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights.
Securing your data
Partnershipinternational.ie will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
Partnershipinternational.ie will store all the personal information you provide [on its secure servers].
[Information relating to electronic transactions entered into via this website will be protected by encryption technology.]
Cross-border data transfers
[In addition, personal information that you submit for publication on the website will be published on the internet and may be available around the world.]
You agree to such cross-border transfers of personal information.
Updating this statement
You should check this page occasionally to ensure you are familiar with any changes.
This website contains links to other websites.
Partnershipinternational.ie is not responsible for the privacy policies or practices of any third party.