Data Protection Policy

Context and overview

Key details

Policy prepared by: E&H Global Ltd
Approved by board / management on: 24 May 2018
Policy became operational on: 24 May 2018
Next review date: 24 May 2019

Introduction

E&H Global Ltd – Juxon House, 100 St Paul’s Churchyard, EC4M 8BU, London, UK 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 E&H Global 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 E&H Global 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

How we protect your information;

Schoolmind uses a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of the Services. We use industry accepted standards and protocols in protecting the sensitive information collected within the Services during transfer by the use of SSL (secure socket layer) encryption as well as in employing physical safeguards in the protection of your information. While we take every precaution in protecting your Personal Information, no method is 100% effective at all times and we make no such guarantees.
For security and analytic purposes, we store information based on your interactions through the Services. The Site automatically logs many of the details regarding all visits and requests to our web servers. This can include the browser type, cookie information, and page requested by a visitor as well as the visitor’s IP address. Schoolmind uses cookies (as explained below) to track the user’s login status during the duration of the user’s browser session.
Analytics are collected on the Site in order to allow us to count the number of hits we receive to our Site as well as to further explore statistically the actions of our users, such as what pages have the highest traffic so as to better optimize our product offerings. These tracking technologies gather information on an aggregate level and are not tied to users’ Personal Information.
In order to protect your Personal Information, the user, this includes administrators, teachers, students and parents of each school, is responsible for maintaining the security and confidentiality of your password together with your login ID/email address that allows you access to the Services. We recommend creating an alpha-numeric password 6-8 characters long combining both upper and lower case letters. Never write this password down and do not share it with others. If you access the Services via partner integration, you may not have a human readable password assigned to you. This authentication process is implemented by our partners and is required to comply with all Schoolmind security standards.
In terms of We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.
Third Party Websites: Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
Schoolmind does not own any data, information or material that You or others submit to the Service in the course of using the Service (“Uploaded Data”). You shall have sole responsibility for the accuracy, quality, integrity, legality, reliability, appropriateness, and intellectual property ownership or right to use any and all Uploaded Data that You submit. Schoolmind shall not be responsible or liable for the deletion, correction, destruction, damage, loss or failure to store any Uploaded Data.
The Customer and/or User are fully liable for the legality of all Uploaded Data stored by the Customer and/or User on the Service. Furthermore the Customer and/or User is fully liable, if such Uploaded data is infringing upon third party rights, and accordingly agrees to indemnify Schoolmind for all claims and losses related to such infringement and/or illegality.
If Schoolmind on its own or through any third party has notice that Uploaded Data stored by the Customer and/or User is in violation of any law or infringes third party rights, Schoolmind shall have the unfettered right to – without liability to the Customer or User – immediately suspend access to such data without prior notice to the User or Customer. The Customer and/or User may be notified by Schoolmind of any such action under this Section, when reasonable and possible.
Upon request by the applicable Customer and/or User, Schoolmind may remove, modify, edit or otherwise alter any applicable Uploaded Data.

People, risks and responsibilities

Policy scope

This policy applies to:

The head office of E&H Global Ltd
All branches of E&H Global Ltd
All staff and volunteers of E&H Global Ltd
All contractors, suppliers and other people working on behalf of E&H Global 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 E&H Global 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.

Responsibilities

Everyone who works for or with E&H Global 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 E&H Global Ltd meets its legal obligations.
E&H Global Ltd 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 E&H Global 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.
E&H Global Ltd 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.
E&H Global Ltd 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.

E&H Global 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.

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 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 smartphones.
All servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to E&H Global 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 or secured online before being transferred electronically. The IT manager can explain how to send data to authorized external contacts.
Personal data should keep in secured international digital platforms.
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 E&H Global 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 E&H Global 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.
E&H Global Ltd will make it easy for data subjects to update the information E&H Global 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 E&H Global 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 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 protected] The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £50 per subject access request. The data controller will aim to provide the relevant data within 14 days.

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, E&H Global 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.

Additional Information

-The servers are located in Germany (https://www.hetzner.com/rechtliches/datenschutz?country=us).

-The Proxy/SSL services are used from Cloudflare (https://www.cloudflare.com/gdpr/introduction/).

– The SSL services are through from Let’s encrypt (https://letsencrypt.org/about/).

-The servers are used in Germany/Ireland from Amazon for backups.

– The Zendesk is used for help-desk (https://www.zendesk.com/company/customers-partners/eu-data-protection/)

– Mobile apps are used including the Google Play for Android mobile apps and Apple store for iOS mobile apps.

Providing information

E&H Global 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.]