Quantum Marketing Solutions Ltd needs to gather and use certain personal data about their clients, suppliers, business contacts 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 Quantum Marketing Solutions Ltd:
- Complies with data protection law and follows 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
This policy document is for internal use and to provide clients with peace-of-mind that Quantum Marketing Solutions Ltd is looking after their data and privacy.
This policy covers all services offered to clients by Quantum Marketing Solutions Ltd and also external services used by Quantum Marketing Solutions Ltd in order to provide them.
Where applicable, third party GDPR policies should be read in conjunction with this policy where data may reside with them.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
GDPR 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
Data Directly Captured and Stored
Quantum Marketing Solutions Ltd requires data from customers to allow us to provide our service. This may include, but is not always limited to:
- Email Address
- Phone Number
- Company Name
- Registered Company Address
This data is stored in an online contacts system and paper copies.
Third-Party Data Controllers and Processors
Quantum Marketing Solutions Ltd employ the services of external companies to help them carry out the services they offer. These companies currently include; Mail Chimp and Firetext (SMS Messaging system).
These companies allow us to:
- Send communications on behalf of clients by email
- Send communications on behalf of clients by SMS Text Messaging
All of our Third-Party Data Controlling partners are either based in the EU, where the same GDPR legislation applies to them; or are based in a location where the EU have deemed their governing legislation as adequate to protect your data privacy.
Data Protection Risks
This policy helps to protect Quantum Marketing Solutions 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 Quantum Marketing Solutions Ltd has some responsibility for ensuring data is collected, stored and handled appropriately.
As the sole director, Mr Glen Cook is ultimately responsible for ensuring that Quantum Marketing Solutions Ltd meets its legal obligations. Appointed as the Data Protection Officer; and registered with the Information Commissioner’s Office (ICO), Mr Cook is responsible for:
- Keeping the board updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions relating to this policy.
- Dealing with requests from individuals to see the data Quantum Marketing Solutions 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.
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Evaluating any third-party services the company is considering using to store or process data.
- Approving any data protection statements attached to communications.
- Addressing any data protection queries from journalists or media outlets like newspapers.
- Ensuring that any marketing initiatives abide by data protection principles.
- 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.
- Quantum Marketing Solutions 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 unauthorised 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.
General Staff Guidelines
Customer Data Storage
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the 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:
- Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
- Data printouts should be disposed of securely 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.
- Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
- 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.
Data Breech Reporting
In line with GDPR regulations, any data breeches which include personal information will be reported to the Information Commissioner’s Office and to anyone affected within 72 hours of being made aware of the breech.
Our primary goal upon being made aware will be to close the breech and secure the systems again.
Personal data is of no value to Quantum Marketing Solutions Ltd and is only stored to allow us to provide the products and services you have asked us to provide. When it is handled, we take the following steps to protect it:
- 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.
- Personal data should never be transferred outside of the European Economic Area, unless to a location where data protection laws are deemed adequate by the EU.
- Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
We do not share personal details of any of our clients to any third parties.
The law requires Quantum Marketing Solutions 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 Quantum Marketing Solutions 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.
- Quantum Marketing Solutions Ltd will make it easy for data subjects to update the information Quantum Marketing Solutions Ltd holds about them. For instance, via the email or telephone.
- 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.
Subject Access Requests
All individuals who are the subject of personal data held by Quantum Marketing Solutions 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 firstname.lastname@example.org
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, Quantum Marketing Solutions 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.
Quantum Marketing Solutions 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 or available from Quantum Marketing Solutions Ltd website.