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  Data Protection (GDPR) Policy

In accordance with the requirements of: -

REGULATION (EU) 2016/679

Context and overview



Key details


 +     Policy prepared by: Steve Smith

+     Approved by board / management on: 20-03-2018

+     Policy became operational on: 20-03-2018

+     Next review date:





C-VIGIL Ltd : marine (CVM) (hereafter referred to as: - CVM Ltd) needs to gather and
use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other
people the organization 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 CVM Ltd:

+     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



Data protection law



The Data Protection Act 1998 describes how organizations — including CVM Ltd —
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 Data Protection Act is underpinned by eight important principles. These say that
personal data must:

1.   Be processed fairly and lawfully
2.   Be obtained only for specific, lawful purposes
3.   Be adequate, relevant and not excessive
4.   Be accurate and kept up to date
5.   Not be held for any longer than necessary
6.   Processed in accordance with the rights of data subjects
7.   Be protected in appropriate ways
8.   Not be transferred outside the European Economic Area (EEA), unless that
      country or territory also ensures an adequate level of protection



People, risks and responsibilities



Policy scope



This policy applies to:

+     The head office of CVM Ltd
+     All branches of CVM Ltd
+     All staff and volunteers of CVM Ltd
+     All contractors, suppliers and other people working on behalf of CVM Ltd
+     It applies to all data that the company holds relating to identifiable
       individuals, even if that information technically falls outside of the Data
       Protection Act 1998.

This can include:

+     Names of individuals
+     Postal addresses
+     Email addresses
+     Telephone numbers
+     … plus, any other information relating to individuals



Data protection risks



This policy helps to protect CVM Ltd from some very real data security risks,

+     Breaches of confidentiality. For instance, information being given out
+     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.






Everyone who works for or with CVM Ltd 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 CVM Ltd
       meets its legal obligations.
+     The data protection officer (DPO), Steve Smith, 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 CVM Ltd
                      holds about them (also called ‘subject access requests’).
               +     Checking and approving any contracts or agreements with third
                      parties that may handle the company’s sensitive data.
+     The IT manager, Steve Smith, 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.
               +     Evaluating any third-party services, the company is considering using
                      to store or process data. For instance, cloud computing services.
+     The marketing manager, Steve Smith, 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.



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 line managers.
   CVM Ltd will provide training to all employees to help them understand their
       responsibilities when handling data.
+     Employees should keep all data secure, by taking sensible precautions and
       following the guidelines below.
+     In particular, strong passwords must be used, and they should never be
+     Personal data should not be disclosed to unauthorized people, either within
       the company or externally.
+     Data should be regularly reviewed and updated if it is found to be out of
       date. If no longer required, it should be deleted and disposed of.
+     Employees should request help from their line manager or the data
       protection officer if they are unsure about any aspect of data protection.



Data storage



These rules describe how and where data should be safely stored. Questions about
storing data safely can be directed to the IT manager or data controller.

When data is stored on paper, it should be kept in a secure place where
unauthorized 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
       unauthorized people could see them
, like on a printer.
+     Data printouts should be shredded and disposed of securely when no longer

When data is stored electronically, it must be protected from unauthorized 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 (like a CD or 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 services.
+     Servers containing personal data should be sited in a secure location, away
       from general office space.
+     Data should be backed up frequently. Those backups should be tested
       regularly, in line with the company’s standard backup procedures.
+     Data should never be saved directly to laptops or other mobile devices like
       tablets or smart phones.
+     All servers and computers containing data should be protected by
       security software and a firewall



Data use



Personal data is of no value to CVM Ltd 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. It should never be sent by
       email, as this form of communication is not secure.
+     Data must be encrypted before being transferred electronically. The IT
       manager can explain how to send data to authorized 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 any data.



Data accuracy



The law requires CVM Ltd 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
CVM Ltd 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.
+     CVM Ltd will make it easy for data subjects to update the information CVM
       Ltd 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 on their stored telephone 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 six months



Subject access requests



All individuals who are the subject of personal data held by CVM Ltd 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 some 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 controller at [email address]. The data controller can supply a standard request
form, although individuals do not have to use this.

The data controller will always verify the identity of anyone making a subject access
request before handing over any information.



Disclosing data for other reasons



In certain circumstances, the Data Protection Act allows personal data to be
disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, CVM Ltd will disclose requested data. However, the data
controller will ensure the request is legitimate, seeking assistance from the board
and from the company’s legal advisers where necessary.



Providing information


  CVM Ltd 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 on request. A version of this statement is also available on the
company’s website.
  C-VIGIL LTD : marine (CVM)  
  The Barn +44 (0)1244 879 279
  Bryntirion Road  
  CH6 6DS, UK Find Us
Company Reg No: 04407624   |   ISO 9001 Reg No: GB 2001 654   |   VAT Reg No: 804 6004 68