Data protection policy
Context and overview
Approved on: 2018-02-13
Policy became operational on: 2018-02-13, replacing previous data protection policy
Next review date: 2018-05-15
46elks AB needs to gather and use certain information about individuals.
These can include customers, customer data like phonenumbers and text messages, 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.
This policy exists to protect customer data
This data protection policy ensures 46elks AB:
- 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
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.
This policy is designed to comply with the eight important principles:
- 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
This policy applies to:
The head office of 46elks AB
All branches of 46elks AB
All staff and volunteers of 46elks AB
All contractors, suppliers and other people working on behalf of 46elks AB
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
- Temporary password
- plus any other information relating to individuals
Data protection risks
This policy helps to protect 46elks AB from 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 46elks AB 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 46elks AB meets its
The CEO is responsible for:
- Keeping the board updated about data protection responsibilities, risks and issues.
- 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. For instance, cloud computing services.
- Performing regular checks and scans to ensure security hardware and software is functioning properly.
- Approving any data protection statements attached to communications such as emails and letters.
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
The Data Protection Officer, Martin Harari Thuresson, is responsible for:
- 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 46elks AB holds about them (also called ‘subject access requests’).
- Addressing any data protection queries from journalists or media outlets like newspapers.
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.
- 46elks AB will provide training to all employees to help them understand their responsibilities when handling data, the training is done in the company bi anual company conference as well as when a new person starts working for 46elks.
- 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.
Employees should request help from their manager 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 unauthorised people cannot see it.
Sensitive data like, but not limited to, personal data should never been stored on paper.
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.
- Two factor authentication should be used when possible.
- If data is stored on removable media (like external hard-drive, USB device, Tape, CD or DVD), these should be kept locked away securely when not being used.
- Data should only be stored on designated drives and servers owned by 46elks, and should not be uploaded to any cloud computing services, without prior specific consent from company CEO.
- 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 a firewall.
- All servers and computers should be updated with the latest security updates.
- All software to be installed on servers must be signed digitally by an trusted organisation or compiled from controlled source code.
Personal data is of no value to 46elks AB 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 not be sent by email, as this form of communication is not secure.
- Data should be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
- Personal data should never be transferred outside of the European Economic Area. Unless an explicit agreement is signed by the personal data owners and approved by the CEO.
- Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires 46elks AB 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 46elks AB 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.
- 46elks AB will make it easy for data subjects to update the information 46elks AB holds about them. For instance, via the 46elks dashboard.
- 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 46elks AB 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 address]. The data controller can supply a standard request form, although individuals do not have to use this.
- Individuals will be charged per subject access request according to the Termes of Service. 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 any information.
- When data is owed by a customer of 46elks, any data request is redirected to the costumer.
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, 46elks AB will disclose requested data. However, the CEO will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary. When possible data owners will be informed about data disclosed to law enforcement agencies.
46elks AB 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
This is available on the 46elks homepage at: https://www.46elks.com/privacy-policy
CEO, Johannes Ridderstedt
Data Protection Officer, Martin Harari Thuresson