EAZYCITY LTD – DATA PROTECTION POLICY

INTRODUCTION:
EazyCity Ltd needs to gather and use certain information about individuals
These can include can include customers, 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 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 EazyCity Ltd:
• Complies with data protection law and follows good practice
• Protects the rights of customers, staff and partners
• Is open about how it stores and processed individuals’ data
• Protects itself from the risks of data breaches

DATA PROTECTION LAW:
The General Data Protection Regulation 2106/679 describe how organisations – including EazyCity 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 General Data Protection Regulation is underpinned by 8 important principles. These state that personal date must:
1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside the EU, unless that country or territory also ensures an adequate level of protection

PEOPLE, RISK AND RESPONSIBILITIES:
POLICY SCOPE
The policy applies to:
• The head office of EazyCity Ltd located at 112 Oliver Plunkett St
• All branches of EazyCity Ltd
• All staff of EazyCity Ltd
• All contractors and people working on behalf of EazyCity Ltd
It applies to all data that the company holds relating to living individual, even if that information technically falls outside of the General Data Protection Regulation 2016/679. This can include:
• Name of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Plus any other information relating directly or indirectly to individuals

DATA PROTECTION RISKS
This policy helps to protect EazyCity 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 EazyCity 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.

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 direct manager
• EazyCity Ltd will provide training to all employees to help them understand their reponsibilities with handling data
• Employees should keep all data secure, by taking sensible precautions
• Personal data should not be disclosed to unauthorised people, either within the company or externally
• Data should be reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

DATA STORAGE
These rules describe how and where data should be safely stored.
• When data is stored on paper, it should be kept in a secure place 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 should be kept in a locked drawer or filing cabinet
• Employees should make sure paper and printouts are not left where unauthorised people could see them eg on printer
• Data printouts should be shredded and disposed of safely when no longer required

When data is stored electronically, it must be protected from unauthorised 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 (eg CD/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 service
• Servers containing personal should be sited in a secure location
• Data should be backed up frequently. Those back-ups should be tested regularly in line with the company’s standard back up procedures
• Data should never be saved directly to laptops or other mobile devices like tables or smart phones
• All servers and computers containing data should be protected by approved security software and a firewall.

DATA USE
Personal data is of no use to EazyCity 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. IT provider can explain how to send data to authorised external contacts
• Personal data should never be transferred outside of the European Economic Area.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of the data

DATA ACCURACY
The law requires EazyCity 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 EazyCity 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
• EazyCity will make it easy for data subjects to update the information EazyCity 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 via saved mobile phone 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 6 months

SUBJECT ACCESS REQUEST
All individuals who are the subject of personal data held by EazyCity 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.

To access your data simply complete the form (INSERT SUBJECT ACCCESS REQUEST FORM) and send via email to [email protected] or post to 112 Oliver Plunkett St, Cork. Please note proof of identification will also be required to authenticate the 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 cannot be charged to honour a subject access request. The data controller will aim to provide the relevant data within 30 days.
The data controller will always verify the identity of anyone making a subject access request before handing over information.

DISCLOSING DATA FOR OTHER REASONS
In certain circumstance, the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstance, EazyCity Ltd will disclose requested data. However the data controller will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.

PROVIDING INFORMATION
EazyCity 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.