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The Knot Agency Confidentiality and Data Protection Policy

Scope & purpose

In the course of performing its activities, The Knot Agency may obtain, receive or otherwise become aware of confidential information relating to its clients or to an individual’s personal data.  The Knot Agency is committed to ensuring the confidentiality and integrity of this information and or data.  It will at all times fulfil data protection requirements placed on it by law and will in particular ensure the individual’s right to privacy, and their right to exercise control over data about themselves.

 

The policy applies to:

  • all employees of The Knot Agency,

  • all contractors, suppliers and other people working on behalf of The Knot Agency

  • its clients, and to others who may be given access to data processed by The Knot Agency.

 

All staff with access to personal or confidential data must be trained on the contents of this policy.

 

This policy applies to the following information, but is not limited to:

  • A client’s business, business plans or affairs, which information is proprietary and confidential in nature.

  • 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

  • Any other information relating to individuals

 

The purpose of this policy is to enable The Knot Agency to:

  • comply with the law in respect of the data it holds about individuals

  • follow good practice

  • protect the rights of any clients, staff or partners of The Knot Agency

  • protect The Knot Agency from the consequences of a breach of its responsibilities

 

Data Protection Law

The Data Protection Act 1998 describes how organisations, including The Knot Agency, must collect, handle and store personal information.  These rules apply regardless of whether data is stores 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 Data Protection Act 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 protection risks

This policy helps to protect The Knot Agency from 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 The Knot Agency has some responsibility for ensuring data is collected, stored and handled appropriately, and in line with this policy and data protection principles.

 

The Director, Chris Jones, is ultimately responsible for the following:

  • Ensuring The Knot Agency meets its legal obligations

  • Reviewing all confidentiality and 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 confidentiality and data protection questions from staff and anyone else covered by this policy.

  • Dealing with requests from individuals to see the data that The Knot Agency holds about them (also called ‘subject access requests’).

  • Checking and approving any contracts or agreements with third parties that may handle the company’s or clients of the company’s sensitive data

  • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.

  • Performing regular checks and scans to ensure security hardware and software is functioning properly.

  • Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services

  • Approving any data protection statements attached to communications such as emails and letters.

  • Addressing any data protection queries from journalists or media outlets like newspapers.

  • Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

 

General staff/contractor 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, the permission of The Knot Agency’s Directors must be sought.

  • The Knot Agency will provide training to all employees/contractors to help them understand their responsibilities when handling data.

  • Employees/contractors 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/contractors should request help if they are unsure about any aspect of data protection.

 

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.

  • Paper and printouts should not be left where unauthorised people could see them.

  • Data printouts should be shredded and 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.

  • If data is stored on removable media (like a CD or 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 services.

  • Data should be backed up frequently. Those backups should be tested regularly.

  • 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 use

Personal data is of no value to The Knot Agency 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.

  • 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 any data.

 

Data accuracy

The law requires The Knot Agency 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 The Knot Agency 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.

  • Data should be updated as inaccuracies are discovered.

  • Ensure marketing databases are checked against industry suppression files every six months.

 

Subject access requests

All individuals who are the subject of personal data held by The Knot Agency 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 Chris.Jones@Kn8t.com, who will aim to provide the relevant data within 14 days.  The identity of anyone making a subject access must be verified 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, The Knot Agency will disclose requested data after ensuring that the request is legitimate, seeking assistance the company’s legal advisers where necessary.

 

Providing information

The Knot Agency aims to ensure that individuals are aware that their data is being processed at point of collection, and that they understand:

  • How the data is being used

  • How to exercise their rights

 

Website Specific Data

We use Google Analytics to understand who is visiting the The Knot Agency website. This helps us to improve the content to suit the majority of users. Google Analytics records which pages you view within the site, how you arrived at the site and some basic information about your computer. All of the information is anonymous, so we do not know anything about you, just that somebody visited our site.

 

The information collected from Analytics helps us to understand what parts of the site are most popular, how people arrive at the site and so on. Like most websites, we use this information to improve the website.

 

Linkedin, Facebook and other social networks

 

These social networks provide social buttons such as the "like" and "Tweet" buttons.  To do so, we embed code that they provide and we do not control this ourselves. In order for these buttons to function, they know if you are logged in; for example Facebook use this to say that "x of your friends like this". We do not have any access to that infomation, nor can we control how those networks use it.

 

Social networks could know that you are viewing this website, if you use their services (they may not, but there is a chance their policies may change in the future without us knowing). As kn8t.com is suitable for all audiences, then this is unlikely to be a concern for most users.

 

 

Policy Prepared by: Chris Jones

Policy operational on: 01/06/2017

Next Review date: 01/06/2021

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