Data Protection Policy
Effective Date: April 1st 2019 Notice Version: 1.7
Data Controller Contact Information
MaEiOu International clt
Beechworth, Victoria, 3747
Commonwealth of Australia
This
document governs the Data Protection policy of our websites.
Policy prepared by:
MaEiOu International clt
Date
this policy was last updated: April 1st 2019
Introduction
MaEiOu International cltneeds to collect
and use certain personal data and information about individuals.
These individuals can include customers, suppliers, business contacts,
employees, and other people whom the organization has a relationship with or may
need to contact.
This policy describes how these personal
data must be collected, processed, and stored to meet data protection standards
and comply with the law.
The
reason for this policy
This data protection policy explains how
MaEiOu International clt:
⦁ complies with data protection laws and
follows good practice
⦁ protects the rights of employees,
partners, customers, and contractors
⦁
explains how it stores and processes individuals’ data
⦁
helps protect personal data from the risks of data breach
Data
protection laws
MaEiOu International clt is committed to
processing data in accordance with its responsibilities under the General Data
Protection Regulation (GDPR) and other data protection and privacy laws.
-These data protection and privacy laws describe how organizations including
MaEiOu International clt must collect, process, and store personal information.
-These rules apply regardless of whether
data are stored electronically, on paper, or in other formats.
-To
comply with the law personal information must be collected and used fairly,
stored safely, and not disclosed unlawfully.
Article 5 of the GDPR requires that
personal data will be:
a. processed lawfully, fairly, and
transparently in relation to individuals
b. collected for specified, explicit,
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, or statistical purposes will be
considered compatible with the initial purposes
c. adequate, relevant, and limited to
what is necessary in relation to the purposes for which they are processed
d. accurate and, where necessary, kept up
to date; every reasonable step must be taken to make sure that personal data
that are inaccurate with regard to the purposes for which they are processed,
are immediately erased or rectified
e. 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 in the public interest, scientific or historical research, or
statistical purposes subject to implementation of the appropriate technical and
organizational measures required by the GDPR in order to safeguard the rights
and freedoms of individuals
f. processed in a manner that ensures
appropriate security of the personal data, including protection against
unauthorized or unlawful processing; accidental loss, destruction, or damage;
using appropriate technical or organizational measures.
People, risks, responsibilities, and
policy scope
This policy applies to:
⦁ the head office of MaEiOu International
clt
⦁ all branches of MaEiOu International
clt
⦁ all employees of MaEiOu International
clt
⦁ all suppliers, contractors, and other
people working on behalf of
MaEiOu International clt.
It
applies to all data that the company holds relating to identifiable individuals,
even if that information technically falls outside some privacy and data
protection laws. This can include the following personal data:
⦁ names of individuals
⦁
postal addresses
⦁ email addresses
⦁
telephone numbers
⦁ other personal information about
individuals.
Data protection risks
This policy helps to protect MaEiOu
International clt from data security risks, including:
⦁ breaches of confidentiality, for
example information being given out or exposed without proper authorization
⦁ failing to give choice, for example,
all individuals should be free to choose how the company uses data relating to
them
⦁ reputational damage, for example, the
company could suffer if unauthorized individuals successfully gained access to
sensitive data.
Responsibilities
Everyone who works for or with MaEiOu
International clt has some responsibility for making sure that data are
collected, stored, and processed appropriately. Each individual who handles
personal data must make sure that the data are handled and processed in line
with this policy and the principles of data protection.
These people have key areas of
responsibility:
The board of directors is ultimately
responsible for making sure that MaEiOu International clt meets its legal
obligations about data protection laws.
The data privacy officer is responsible
for:
⦁ keeping the MaEiOu International clt
updated about data protection laws, responsibilities, risks, and issues
⦁
reviewing all data protection procedures and related policies on a periodic
basis
⦁ providing data protection training and
advice to people covered by this policy
⦁
responding to data protection questions from staff and anyone else covered by
this policy
⦁ responding to requests from individuals
to see the data that MaEiOu International clt holds about them
(also called "subject access requests")
⦁
reviewing and approving any agreements or contracts with third parties that may
process the company's personal and sensitive data.
The
IT manager is responsible for:
⦁ making sure that all computer and
electronic systems, services, and equipment used for storing and processing data
meet acceptable security standards
⦁ performing regular security checks and
scans to make sure that hardware and
⦁
software is functioning properly
⦁ evaluating any third-party services
that the company is considering using to collect, process, or store data.
The
marketing manager is responsible for:
⦁ approving any data protection
statements attached to
⦁ communications such as emails and
letters
⦁ addressing data protection queries from
journalists or media
⦁ outlets
⦁
where necessary, working with other employees to make sure that marketing
initiatives
adhere to the principles of data
protection.
General employee 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 with others without appropriate authorization. When
access to and the sharing of confidential information is required, employees can
request it from their supervisors.
⦁ MaEiOu International clt will provide
training to all employees to help them understand their responsibilities when
handling data and confidential information.
⦁
Employees should keep all data secure by taking reasonable precautions and
following the guidelines below.
⦁ Strong passwords must be used and
should never be shared.
⦁ Personal data should not be disclosed
to unauthorized people within the company nor externally.
⦁
Data should be regularly reviewed and updated if they are found to be out of
date. If no longer required, they should be deleted and disposed of using
appropriate security procedures.
⦁ Employees should request help from
their supervisors or a data protection officer if they are unsure about any
aspect of data protection procedures.
Data
storage
⦁ These rules describe how and where
personal data should be safely stored. Questions about safely storing personal
data can be directed to the IT manager or data controller.
⦁
When personal data are stored on paper, they should be kept in a secure place
where unauthorized people cannot see them.
⦁
These guidelines also apply to personal data that are usually stored
electronically but have been printed out for some reason:
⦁
When not required, the paper or files should be kept in a locked drawer, filing
cabinet, or environment.
⦁ Employees and contractors should make
sure that paper and printouts are not left where unauthorized people could see
them, such as in copiers or printers.
⦁
Printouts of personal data should be shredded and disposed of securely when no
longer needed.
⦁ When data are stored electronically,
they must be protected from unauthorized access, accidental deletion, and
malicious hacking attempts.
⦁ Personal data should be protected by
strong passwords that are changed regularly and never shared among employees nor
contractors.
⦁ If personal data are stored on
removable media such as a DVD, CD, or portable drive, they should be kept locked
away securely when not used.
⦁ Personal data should only be stored on
designated drives and servers and should only be uploaded to approved and secure
cloud computing services.
⦁ Servers containing personal data should
be situated in a secure location away from general offices and visitor traffic.
⦁ All data should be backed up frequently
and securely. Backups should regularly be tested in line with the company’s
standard backup procedures.
⦁ Personal data should never be saved
directly to laptops, portable drives, tablets, nor smart phones.
⦁
All computers and servers containing personal data should be protected by
approved firewall and security software.
Personal data use
When personal data are accessed, their
use can be at the greatest risk of theft, loss, or corruption:
⦁ when working with personal data,
employees, contractors, and others should make sure that their computers are
always password protected and locked when left unattended.
⦁
personal data should not be shared with anyone who is not authorized to see
them. Unless encrypted, they should never be sent by email, as most email
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 out of the European Union without appropriate consent, binding
corporate rules, compelling legitimate interests, specific derogations, or other
approved processes.
⦁ employees, contractors, and others
should not save copies of personal data to their own computers or other devices.
Always access and update the central copy of any personal data.
Personal data accuracy
⦁ The law requires MaEiOu International
clt to take reasonable steps to make sure that personal data are kept accurate
and up to date.
⦁ The more important it is that the
personal data are accurate, the more effort MaEiOu International clt should put
into guaranteeing their accuracy.
⦁ It is the responsibility of all
employees, contractors, and others who work with personal data to take
reasonable steps to keep personal data as accurate and up to date as possible.
⦁ Personal data will be held in as few
places as necessary. Company employees and contractors should not create
unnecessary additional data sets.
⦁ Company employees and contractors
should take every opportunity to make sure that data are updated. For example,
by confirming customers’ information when they call.
⦁
MaEiOu International clt will make it easy for data subjects to update the
information MaEiOu International clt holds about them. As an example, by using
the company website, Internet portal, or by phone.
⦁
Personal data should be updated when 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 make sure that marketing databases
are checked and updated against industry suppression files yearly.
Subject access requests
All individuals who are the subjects of
personal data held by MaEiOu International clt are entitled to:
⦁ ask what information the company holds
about them and why
⦁ ask how to gain access to it
⦁
know how to keep it up to date
⦁ know how the company is meeting its
data protection obligations.
If
an individual contacts the company requesting this information, this is called a
subject access request (SAR).
SARs from individuals should be made by
email addressed to the data controller by using the contact information at the
top of this policy. The data controller can supply a standard request form,
although individuals do not have to use it.
The data controller will provide the
relevant data within 30 days from receiving the request. The data controller
will always verify the identity of anyone making a subject access request before
providing them with any information.
Disclosing personal data for other
reasons
In certain circumstances privacy laws
allow personal data to be disclosed to law enforcement agencies without the
consent of the data subject. Under these circumstances MaEiOu International clt
will disclose the requested data. However, the data controller will make sure
that the request is legitimate and seek assistance from legal counsel if
necessary.
Data Breach
In the event of a breach of security
leading to accidental or unlawful destruction, loss, alteration, unauthorized
disclosure of, or access to personal data the MaEiOu International clt will
assess the risk to people's rights and freedoms and if required report this
breach to the appropriate authority.
Providing information
MaEiOu International clt does its best to
make sure that individuals are aware that their data are being processed, and
that they understand:
⦁ how their personal data are being used
⦁ how to exercise their rights under the
law.
The
company has a comprehensive privacy notice explaining how data relating to
individuals are collected, processed, stored, shared, and protected by the
company.
This data protection policy notice is
available on request.
A current version of this notice is also
available on the company's website.
If
you have any questions about data protection policy, please contact us using the
information at the top of this privacy notice.