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E. J. Taylor & Sons Limited, Quinlan Court

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Countryside Properties - Fortuna Park, Colchester Rose Builders Ltd - Parsonage House, Marks Tey, Colchester Taylor Woodrow Ltd - Abbortsford Park, Bury St Edmunds, Suffolk David Wilson Homes - Hartswood Mews, Takeley Roberge Site Management

Latest News from Roberge

Data Protection Policy Items 22-26 of 26

Posted: 23/05/18 09:38

Data Protection Policy Items 22-26 of 26

22.     Data Security - IT Security

The Company shall ensure that the following measures are taken with respect to IT and information security:

22.1           All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. [All software used by the Company is designed to require such passwords.];

22.2           Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

22.3           All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates [not more than 1 week after the updates are made available by the publisher or manufacturer] OR [as soon as reasonably and practically possible] [, unless there are valid technical reasons not to do so]; and

22.4           No software may be installed on any Company-owned computer or device without the prior approval of the The Company’s Data Protection Officer.

 

23.             Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

23.1           All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy;

23.2           Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;

23.3           All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;

23.4           All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;

23.5           All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;

23.6           Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;

23.7           All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;

23.8           The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;

23.9           All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;

23.10        All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the GDPR; and

23.11        Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

 

24.             Transferring Personal Data to a Country Outside the EEA

24.1           The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.

24.2           The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:

24.2.1      The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;

24.2.2      The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;

24.2.3      The transfer is made with the informed consent of the relevant data subject(s);

24.2.4      The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);

24.2.5      The transfer is necessary for important public interest reasons;

24.2.6      The transfer is necessary for the conduct of legal claims;

24.2.7      The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or

24.2.8      The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

 

25.             Data Breach Notification

25.1           All personal data breaches must be reported immediately to the Company’s Data Protection Officer.

25.2           If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.

25.3           In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.

25.4           Data breach notifications shall include the following information:

25.4.1      The categories and approximate number of data subjects concerned;

25.4.2      The categories and approximate number of personal data records concerned;

25.4.3      The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);

25.4.4      The likely consequences of the breach;

25.4.5      Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

 

26.             Implementation of Policy

This Policy shall be deemed effective as of 25th May 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.