Company Name: ku.dos online training (“the Company”)
An Eclectic Tangent Production – a ‘Warren Kemp’ product
Policy Name: Information Security and Data Protection
Date: May 21st 2018
The General Data Protection Regulations 2018 – GDPR:
The Company processes personal data in relation to its own staff, training delegates and individual client contacts – therefore it is a “data processor” for the purposes of the General Data Protection Regulations 2018.
The Company holds personal data on individuals (“data subjects”) for the following general purposes:
- Advertising, marketing and public relations.
- Accounts and records.
- Design, delivery and evaluation of online learning and development programmes
The General Data Protection Regulations data principles:
The General Data Protection Regulations 2018 requires the Company as data processor to process data in accordance with the principles of data protection. 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 is inaccurate, having regard to the purposes for which they are processed, is 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.
“Personal data” means, any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
“Processing” means obtaining, recording or holding the data or carrying out any operation or set of operations on the data. It includes organising, adapting and amending the data, retrieval, consultation and use of the data, disclosing and erasure or destruction of the data. It is difficult to envisage any activity involving data, which does not amount to processing. It applies to any processing that is carried out on computer including any type of computer however described, mainframe, desktop, laptop, iPad, Blackberry ® or other mobile device.
Personal data should be reviewed on a regular basis to ensure that it is accurate, relevant and up to date and those people listed in the Appendix shall be responsible for doing this.
Sensitive personal data:
Article 9 of the GDPR refers to sensitive personal data as “special categories of personal data”. The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual.
Personal data in respect of the following is “sensitive personal data” and will not be gathered by the company unless in specific circumstances and not without prior consent. Any information held on any of these matters WILL NOT be passed on to any third party.
- Any offence committed or alleged to be committed by them.
- Proceedings in relation to any offence and any sentence passed.
- Physical or mental health or condition.
- Racial or ethnic origins.
- Sexual life.
- Political opinions.
- Religious beliefs or beliefs of a similar nature.
- Whether someone is a member of a trade union.
From a security point of view, only those staff listed in the Appendix are permitted to add, amend or delete personal data from the Company’s database(s) (“database” includes paper records or records stored electronically). However all staff are responsible for notifying those listed where information is known to be old, inaccurate or out of date. In addition all employees should ensure that adequate security measures are in place. For example:
- Computer screens should not be left open by individuals who have access to personal data.
- Passwords should not be disclosed.
- Email should be used with care.
- Personnel files and other personal data should be stored in a place in which any unauthorised attempts to access them will be noticed. They should not be removed from their usual place of storage without good reason.
- Personnel files should always be locked away when not in use and when in use should not be left unattended.
- Any breaches of security should be treated as a disciplinary issue.
- Care should be taken when sending personal data in internal or external mail.
- Destroying or disposing of personal data counts as processing. Therefore care should be taken in the disposal of any personal data to ensure that it is appropriate. Such material should be shredded or stored as confidential waste awaiting safe destruction.
It should be remembered that the incorrect processing of personal data e.g. sending an individual’s details to the wrong person, allowing unauthorised persons access to personal data, or sending information out for purposes for which the individual did not give their consent, may give rise to a breach of contract and/or negligence leading to a claim against the Company for damages from an employee, work-seeker or client contact. A failure to observe the contents of this policy will be treated as a disciplinary offence.
Subject access requests:
Under the GDPR, individuals will have the right to obtain:
- confirmation that their data is being processed;
- access to their personal data; and
- other supplementary information – this largely corresponds to the information that should be provided in a privacy notice (see Article 15)
The company will provide a copy of the information free of charge, however, the company reserves the right to charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive.
The company may also charge a reasonable fee to comply with requests for further copies of the same information, though there will be no charge for all subsequent access requests.
Any fee will be based on the administrative cost of providing the information.
Information will be provided without delay and at the latest within one month of receipt.
Where requests are complex or numerous the period of compliance will be extended by a further two months. If this is the case, the individual will be informed within one month of the receipt of the request with an explanation of why the extension is necessary
Where requests are manifestly unfounded or excessive, in particular because they are repetitive, the company will:
- charge a reasonable fee taking into account the administrative costs of providing the information; or
- refuse to respond.
Where response to a request is refused, a clear explanation will be given to the individual who will, within one month be informed of their right to complain to the supervisory authority and to a judicial remedy without undue delay.
List names of those responsible for adding, amending or deleting data; and responsible for responding to subject access requests
Warren Kemp; Jessica Shailes
c/o Recruitment Matters International Ltd
Sleaford Station Business Centre
Lincs NG34 7RG
T: +44(0) 1529 410586
Cookies In Use on This Site
Cookies and how they Benefit You
Cookies are small text files that are placed on your computer or mobile phone when you browse websites
Our cookies help us:
- Make our website work as you’d expect
- Save you having to login every time you visit the site
- Remember your settings during and between visits
- Improve the speed/security of the site
- Allow you to share pages with social networks like Facebook
- Continuously improve our website for you
- Make our marketing more efficient (ultimately helping us to offer the service we do at the price we do)
- Collect any personally identifiable information (without your express permission)
- Collect any sensitive information (without your express permission)
- Pass personally identifiable data to third parties
You can learn more about all the cookies we use below
More about our Cookies
Website Function Cookies
Our own cookies
- Making our shopping basket and checkout work
- Determining if you are logged in or not
- Remembering your search settings
- Remembering if you have accepted our terms and conditions
There is no way to prevent these cookies being set other than to not use our site.
Third party functions
Disabling these cookies will likely break the functions offered by these third parties
Social Website Cookies
So you can easily “Like” or share our content on the likes of Facebook and Twitter we have included sharing buttons on our site.
Cookies are set by:
The privacy implications on this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks.
Site Improvement Cookies
We regularly test new designs or site features on our site. We do this by showing slightly different versions of our website to different people and anonymously monitoring how our site visitors respond to these different versions. Ultimately this helps us to offer you a better website.
Visitor Statistics Cookies
Cookies are widely used in online advertising. Neither us, advertisers or our advertising partners can gain personally identifiable information from these cookies.
You can learn more about online advertising at http://www.youronlinechoices.com . You can opt-out of almost all advertising cookies at http://www.youronlinechoices.com/uk/your-ad-choices although we would prefer that you didn’t as ultimately adverts help keep much of the internet free. It is also worth noting that opting out of advertising cookies will not mean you won’t see adverts, just simply that they won’t be tailored to you any longer.
You may notice that sometimes after visiting a site you see increased numbers of adverts from the site you visited. This is because advertisers, including ourselves pay for these adverts. The technology to do this is made possible by cookies and as such we may place a so called “remarketing cookie” during your visit. We use these adverts to offer special offers etc to encourage you to come back to our site. Don’t worry we are unable to proactively reach out to you as the whole process is entirely anonymised. You can opt out of these cookies at anytime as explained above.
We have a number of partners who promote our service on a success-only basis (i.e. instead of paying for advertising, we pay them commissions on sales). Cookies are required to allow us to reward these partners and these cookies are usually provided by specialist companies (known as affiliate networks). Neither us, the networks, or the partner advertising or recommending our services are able to identify you personally. We ask you to support us by allowing these cookies which ultimately help us to offer you the service we do at the price we do. Our affiliate cookies are provided by:
Turning Cookies Off
You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies (Learn how here). Doing so however will likely limit the functionality of our’s and a large proportion of the world’s websites as cookies are a standard part of most modern websites
It may be that you concerns around cookies relate to so called “spyware”. Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive. Learn more about managing cookies with antispyware software.
The cookie information text on this site was derived from content provided by Attacat Internet Marketing http://www.attacat.co.uk/, a marketing agency based in Edinburgh. If you need similar information for your own website you can use their free cookie audit tool.