Within the UK and EU, businesses such as Olorisk Ltd, which acquire, process or store personal information of clients, employees or sub-contractors that have EU or UK citizenship must register for, and comply with, the principles of the Data Protection Act 2018.
Throughout this document, Olorisk Ltd will be referred to as the “Company”, and the term “employees” shall refer to employees, sub-contractors, vendors and any other contracted business representative of the Company.
1. Data Protection Principles
The Company is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
2. General Provisions
This policy applies to all personal data processed by the Company.
The Register of Systems shall be reviewed at least annually.
Individuals have the right to access their personal data and any such requests made to the Company shall be dealt with in a timely manner.
4. Lawful Purposes
All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
The Company shall note the appropriate lawful basis in the Register of Systems.
Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available and systems are in place to ensure such revocation is reflected accurately in the Company’s systems.
5. Data Minimisation
The Company shall ensure that personal data held is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
The Company shall take all reasonable steps to ensure personal data is accurate.
Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
7. Access to Your Information and Correction
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the following address:
Green Park House
15 Stratton Street
We will keep your personal information for one year from your last interaction with us unless we have a legal obligation to retain that information for a different period of time.
8. Sharing of Personal Information
The Company processes data for the “purposes” of enabling us to provide a service to our clients, manage and support our employees, maintain our own accounts and records, and to advertise and promote our services.
Types and classes of information processed, relevant to the above “purposes”,
Lifestyle and social circumstances
Education and employment details
Good and services
Personal information is shared as a required function of the Company. The information shared may include name, contact details, family details, financial details, employment details, and goods and services. This information may be about clients, employees and sub-contractors.
The information may be shared with business partners, service providers, employees, sub-contractors, customers and clients.
9. Archiving / Removal
To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
The archiving policy shall consider what data should/must be retained, for how long, and why.
The Company shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
Access to personal data shall be limited to personnel who need access and appropriate security measures will be maintained to avoid unauthorised sharing of information.
When personal data is deleted, this will be done safely such that the data is irrecoverable.
Appropriate back-up and recovery solutions are in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and, if appropriate, report this breach to the ICO (more information on the ICO website).
All efforts will be made to towards a fair resolution of any such breach. However, should persons affected by any such breach believe the resolution to be unfair, you have the right to make a complaint to your local data protection authority and the Information Commissioners Office.