This Policy should be read in conjunction with EPI’s GDPR Data Protection Statement.
- Policy prepared by: Andy Smart
- Approved by board / management on: 22/05/2018
- Policy became operational on: 25/05/2018
- Next review date: 25/05/2019
The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
EPI needs to gather and use certain information about individuals in the course of its business as an up-stream oil and gas consultancy.
These individuals can include customers, consultants, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data must be processed i.e. collected, handled and stored to meet the company’s data protection standards and remain compliant with GDPR requirements for personal data.
The definition of personal data provides for a wide range of personal identifiers, including name, identification number, location data or email addresses and telephone numbers.
The GDPR applies to both automated personal data and to manual filing systems where personal data are accessible according to specific criteria. This could include chronologically ordered sets of manual records containing personal data.
This policy applies to EPI Group (Holdings) Limited (“EPI”), including: –
- All Group subsidiaries and branches:
- All staff and volunteers of EPI
- All contractors, suppliers and other people working on behalf of EPI
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include as a minimum:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
Plus any other information relating to individuals
Principles of GDPR
Article 5 of the GDPR requires that personal data shall be:
a) processed lawfully, fairly and in a transparent manner in relation to individuals;
b) 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, scien-tific or historical research purposes or statistical purposes shall not be considered to be incompatible 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 ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
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 in-sofar 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
f) 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.”
Data Protection Risks
This policy helps to protect EPI from some very real data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- 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 EPI 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 EPI meets its legal obligations.
- The Data Protection Officer, is responsible for the consultants’ data held within ITRIS:
- Keeping the board updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies annually.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and third parties else covered by this policy.
- Dealing with requests from individuals to see the data that EPI holds about them
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
- The IT Manager, 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 may use to store or process data. For instance, cloud computing services.
- Be responsible for ensuring that EPI’s Privacy Statement is posted and kept up to date on the company website as is readily available to all individuals whose person data EPI uses or may use.
- The Business Development Manager, is responsible for personal information held within EPI’s CRM:
- Ensure that all data held on individuals within the CRM has passed the “Legitimate Business Interest Assessment”
- Perform a search annually of the CRM to identify client contacts that have been dormant for three years or more and remove such contacts from the data base (leaving the com-pany details intact).
- Addressing any data protection queries from third parties (Clients) who may inquire as to what personal data we are storing and using.
- Where necessary, working with other staff to ensure marketing initiatives abide by the GDPR principles.
Access to Personal Information
- The only people able to access data covered by this policy should be those who need it for their work. Access is controlled through individual software licenses in the case of the three main IT platforms used (ITRIS, SAGE and Salesforce) and individual access is controlled through unique ID and Password.
- EPI will provide training to all employees to help them understand the requirements of GDPR and their responsibilities when handling personal information.
- Employees should keep all data secure, by taking sensible precautions and following the guide-lines below.
- Strong passwords must be used and they should never be shared.
- Personal information should not be disclosed to unauthorised people, either within the company or externally.
- Consultant’s personal information way only be shared with potential clients with the written approval of the consultant and this approval and acknowledgement must be captured within ITRIS.
- Personal information of consultants, suppliers and past and present employees of EPI will be held securely by the company for a period of seven (7) years from the day that the employee ceased to be employed by EPI or the consultant/supplier ceases to be contracted by EPI.
- All personal information stored and used by EPI will be reviewed and updated every 3 years and if it is found to be out of date or If no longer required, it will 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.
These rules describe how and where data will be safely stored at EPI. Questions about storing data safely can be directed to the IT Manager or Data Protection Officer.
When data is stored on paper, it will be kept under lock and key at the head office of where unauthorised 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 of personal information will be kept in the locked personnel filing cabinet.
- Employees should make sure paper and printouts of personal information are not left where un-authorised people could see them, like on a printer.
- Printouts of personal information will be shredded and disposed of securely when no longer required.
Employee personal information will be stored electronically in the HR area of Sharepoint (cloud) where access is restricted to the Board of Directors and is protected from unauthorised access, accidental deletion and malicious hacking attempts. Consultant personal information will be stored on ITRIS where access is restricted to employees of EPI who have a legitimate need to access such data. Personal information belonging to clients and business associates will be stored electronically in the CRM Salesforce and accessed by licensed authorised EPI employees.
- Personal information should be protected by strong passwords that are changed regularly and never shared between employees.
- Personal information will never be saved directly to laptops or other mobile devices like tablets or smart phones.
- All servers and computers containing personal information will be protected by approved security software and a firewall.
Personal data is of no value to EPI 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 will ensure the screens of their computers are always locked when left unattended.
Subject access requests
All individuals who are the subject of personal information held EPI 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.
The Data Protection Officer 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 GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, EPI will disclose requested data. However, the Data Protection Officer will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
EPI aims to ensure that individuals are aware that their data is being processed, and that they understand:
- How the personal information 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.