Data Protection Policy

Key details

Introduction

GoNetcats SARL needs to gather and use certain information about individuals.

These 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 GoNetcats SARL:

Data protection law

The EU General Data Protection Regulation (GDPR) describes how organisations — including GoNetcats SARL — 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 EU General Data Protection Regulation (GDPR) is underpinned by six important principles. These say that personal data must:

  1. Processed fairly, lawfully and in a transparent manner in relation to the data subject.
  2. Collected for specified, explicit and legitimate purposes and not further processed for other purposes incompatible with those purposes.
  3. Adequate, relevant and limited to what is necessary in relation to the purposes for which data is processed.
  4. Accurate and, where necessary, kept up to date.
  5. Kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed.
  6. Processed in a way 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.

Policy scope

This policy applies to:

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the EU General Data Protection Regulation (GDPR). This can include:

Data protection risks

This policy helps to protect GoNetcats SARL from some very real data security risks, including:

Responsibilities

Everyone who works for or with GoNetcats SARL 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.

People, risks and responsibilities

However, these people have key areas of responsibility:

General staff guidelines

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 unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

Data storage

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

Data use

Personal data is of no value to GoNetcats SARL 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:

The law requires GoNetcats SARL to take reasonable steps to ensure data is kept accurate and up to date.

Data accuracy

The more important it is that the personal data is accurate, the greater the effort GoNetcats SARL 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.

All individuals who are the subject of personal data held by GoNetcats SARL are entitled to:

Subject access requests

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 not be charged 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 EU General Data Protection Regulation (GDPR) allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, GoNetcats SARL 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.

GoNetcats SARL aims to ensure that individuals are aware that their data is being processed, and that they understand:

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.