Axi-dent 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 Axi-dent ltd:
• Complies with data protection law GDPR 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 organisations — including Axi-dent 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:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- 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 Axi-dent ltd
- All branches of Axi-dent Ltd
- All staff and volunteers of Axi-dent Ltd
All contractors, suppliers and other people working on behalf of Axi-dent 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 Axi-dent ltd 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 Axi-dent 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 Axi-dent ltd meets its legal obligations.
The Company, is responsible for:
• Keeping the staff 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 Axi-dent 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 Company 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 Company, 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.
• Axi-dent 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 shared.
• 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.
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 required.
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 approved security software and a firewall.
Personal data is of no value to Axi-dent 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. In particular, 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.
The law requires Axi-dent 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 Axi-dent 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.
- Axi-dent ltd will make it easy for data subjects to update the information 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 Axi-dent 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 an individual contact 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 firstname.lastname@example.org. 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, Axi-dent 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.
Axi-dent 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.]
Amendment: – 20-03-2018 GDPR: –
Axi-dent ltd commit to respecting and protecting your online privacy.
This includes your need and your right to know what we do with the personal information you share with us.
It also guides our company’s policies regarding the management of this data, including how the information is collected, processed, and for what purposes.
The collection of information
Every time you log on to our website your IP (Internet Protocol) address registers on our servers. Your IP address reveals no information other than the number assigned to you. We do not use this technology to get any personal data against your knowledge or free will (i.e., automatically recording e-mail addresses of visitors). Nor do we use it for any purpose other than to help us monitor traffic on our website, or (in case of criminal activity or misuse of our information) to cooperate with law enforcement.
PRIVACY AND DATA PROTECTION NOTICE
1. DATA PROTECTION Axi-dent ltd are committed to protecting and respecting your privacy in accordance with the current Data Protection Legislation (“Legislation”).
2. HOW WE USE YOUR INFORMATION We may use the personal data we hold about you in the following ways: • For the purposes of providing insurance, handling claims and any other related purposes. This may include underwriting decisions made via automated means – this is for the performance of the insurance contract between you and us. • For offering renewal, research or statistical purposes – this is for our legitimate interests: for us to analyze historic activity, to improve our rating algorithms and to help predict future business impact. To further our commercial interests, to enhance our product offering and to develop new systems and processes. • To provide you with information, products or services that you request from us or which we feel may interest you – where you have consented to be contacted for such purposes. • To notify you about changes to our service – this is for our legal and regulatory obligations. • To safeguard against fraud and money laundering and to meet general legal or regulatory obligations – this is for our legal and regulatory obligations.
The provision of such data is conditional for us to be able to provide insurance or manage a claim and, whilst you can withdraw your consent for us to process such data, this may result in us not being able to continue cover, or to process any claims. Where such data is provided to us, it will only be used for the purposes set out above and will be treated securely and in line with this notice.
3. DISCLOSURE OF YOUR PERSONAL DATA We may disclose your personal data to third parties involved in providing products or services to us, or to service providers who perform services on our behalf. These include:
a) Affinity partners;
c) Brokers, agents, third party administrators, reinsurers;
d) Other insurance intermediaries;
e) Medical service providers;
f) Fraud detection agencies;
g) External law firms;
h) External auditors;
i) Regulatory authorities
j) As may be required by law.
4. INTERNATIONAL TRANSFERS OF DATA We do not transfer your personal data to destinations outside the European Economic Area (“EEA”).
5. YOUR RIGHTS You have the right to: a) Ask us not to process your data for marketing purposes. b) See a copy of the personal information we hold about you. c) Ask us to delete any of your personal data (subject to certain exemptions). d) Have any inaccurate or misleading data corrected or deleted. e) Ask us to provide a copy of your data to any controller.
6. MARKETING Where you have provided consent, we only use your reviews submitted to us on social media.
7. RETENTION Your data will not be retained for longer than is necessary and will be managed in accordance with our data retention policy. In most cases the retention period will be for a period of seven (7) years following the expiry of the insurance contract, or our business relationship with you, unless we are required to retain the data for a longer period due to business, legal or regulatory requirements.
Axi-dent ltd may send “cookies” to your computer. Cookies are fragments of data sent through the web server and stored in your hard drive. Cookies can’t read the files stored in your computer, nor can they gather information. The purpose of cookies are just to monitor the traffic on the site, so we know which pages you have visited or customized, making it easier for you to download the information the next time you look at our pages.
Visitors to our websites
When someone visits www.axi-dent.co.uk we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
People who email us
We use Microsoft office to encrypt and protect email traffic. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law. This information will be retained for one year and will not be shared with any other organisations.
People who WhatsApp/Messenger/Text us
We use a third-party provider Facebook & WhatsApp to manage our social media interactions. Text messages are through our mobile supplier EE. If you send us a private or direct message via social media the message will be stored for three months. It will not be shared with any other organisations.