Data protection policy

Context and overview

Key details

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:

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:

People, risks and responsibilities

Policy scope

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:

Data protection risks

This policy helps to protect 46elks AB from data security risks, including:


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 legal obligations.

The CEO is responsible for:

The Data Protection Officer, Martin Harari Thuresson, is responsible for:

General staff guidelines

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 Data should be regularly reviewed and updated if it is found to be out of date.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.

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 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 use

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:

Data accuracy

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.

Subject access requests

All individuals who are the subject of personal data held by 46elks AB are entitled to:

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.

Providing information

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

To these ends, the company has a privacy policy, setting out how data relating to individuals is used by the company. This is available on the 46elks homepage at:

Contact information

CEO, Johannes Ridderstedt

Data Protection Officer, Martin Harari Thuresson