Global Career Company Data Protection Policy
- Policy prepared by: Regina Bluman, OryxAlign
- Approved by/on: 23/05/2018
- Policy became operational on: 23/05/2018
- Next review date: 23/11/2018
Global Career Company 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 Global Career Company:
- 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
General Data Protection Regulation
The General Data Protection Regulation describes how organisations – including Global Career Company – must collect, handle, and stores 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 six important principles. These say that personal data must:
- Be processed lawfully, fairly, and in a transparent manner in relation to individuals;
- Be collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- Be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
- Be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay;
- Be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- Be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.
People, Risks, and Responsibilities
This policy applies to:
- The head office of Global Career Company
- All branches of Global Career Company
- All staff and volunteers of Global Career Company
- All contractors, suppliers, and other people working on behalf of Global Career Company
It applies to all data that the company holds relating to identifiable individuals, including:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Plus any other information that specifically relates to an identifiable individual
Data Protection Risks
This policy helps to protect Global Career Company from some very real data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. 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.
Everyone who works for or with Global Career Company 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 Global Career Company meets its legal obligations.
- The Data Protection Officer 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 Global Career Company holds about them (called “Subject Access Requests”).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
- The Managed IT Services Company, OryxAlign, 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.
- Maintaining our Cyber Essentials and ISO 27001/9001 certifications and ensuring that all data processed by OryxAlign is subject to those standards.
- The Management Associate 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.
Subject Access Requests
All individuals who are the subject of personal data held by Global Career Company are entitled to obtain:
- Confirmation that their data is being processed;
- Access to their personal data; and
- Other supplementary information.
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 Protection Officer at firstname.lastname@example.org. Individuals will not be charged for requesting their data, unless a request is manifestly unfounded or excessive, particularly if it is repetitive. A reasonable fee may be charged to comply with requests for further copies of the same information. This does not mean there will be charges for all subsequent access requests.
Subject’s information will be provided without delay and at the latest within one month of receipt. If requests are complex or numerous, Global Career Company may extend the period of compliance by a further two months. If this is the case, the data subject will be contacted within one month of the receipt of the request, and an explanation will be given to explain why the extension is necessary.
Where requests are manifestly unfounded or excessive, in particular because they are repetitive, Global Career Company can:
- Charge a reasonable fee taking into account the administrative costs of providing the information; or
- Refuse to respond.
Where Global Career Company refuses a request, an explanation will be given to the individual, informing them of their right to complain to the supervisory authority and to a judicial remedy without undue delay and at the latest within one month.
Before providing a data subject with a copy of their information, Global Career Company must verify the identity of the person making the request, using ‘reasonable means’. If the request is made electronically, the company will provide the information in a commonly used electronic format.
Disclosing Data for Other Reasons
In certain circumstances, the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Global Career Company will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and the company’s legal advisers where necessary.
Global Career Company 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 upon request. A version of this statement is also available on the company’s website at www.GlobalCareerCompany.com.