DATA PROTECTION POLICY
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:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- 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;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- 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
- 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.
2. General Provisions
This policy applies to all personal data processed by the Company.
- The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- The Company is registered with the Information Commissioners Office (ICO), (registration number ZA501531). The Company has a nominated Data Protection Officer, who is responsible for the protection of all personal data held by the Company.
- The Company employs a third party supplier for vetting and screening purposes. The third party are registered with the ICO as an organisation that processes personal data (ICO registration number ZA401409).
- 3. Lawful, Fair and Transparent Processing
- To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
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.