1. Data protection principles
PerkZilla is committed to processing data in accordance with its responsibilities under the General Data Protection Regulation (GDPR) and other data protection and privacy laws. These data protection and privacy laws describe how organizations including PerkZilla must collect, process, and store personal information. These rules apply regardless of whether data are stored electronically, on paper, or in other formats. To comply with the law personal information must be collected and used fairly, stored safely, and not disclosed unlawfully.
Article 5 of the GDPR requires that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods than required as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner 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.
2. General provisions
- This policy applies to all personal data processed by PerkZilla.
- The Responsible Person shall take responsibility for PerkZilla’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
Data protection risks
This policy helps to protect PerkZilla from data security risks, including:
- breaches of confidentiality, for example information being given out or exposed without proper authorization
- failing to give choice, for example, all individuals should be free to choose how the company uses data relating to them
- reputational damage, for example, the company could suffer if unauthorized individuals successfully gained access to sensitive data.
Everyone who works for or with PerkZilla has some responsibility for making sure that data are collected, stored, and processed appropriately. Each individual who handles personal data must make sure that the data are handled and processed in line with this policy and the principles of data protection.
General employee 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 with others without appropriate authorization. When access to and the sharing of confidential information is required, employees can request it from their supervisors.
- PerkZilla will provide training to all employees to help them understand their responsibilities when handling data and confidential information.
- Employees should keep all data secure by taking reasonable precautions and following the guidelines below.
- Strong passwords must be used and should never be shared.
- Personal data should not be disclosed to unauthorized people within the company nor externally.
- Data should be regularly reviewed and updated if they are found to be out of date. If no longer required, they should be deleted and disposed of using appropriate security procedures.
- Employees should request help from their supervisors or a data protection officer if they are unsure about any aspect of data protection procedures.
- These rules describe how and where personal data should be safely stored. Questions about safely storing personal data can be directed to the IT manager or data controller.
- When personal data are stored on paper, they should be kept in a secure place where unauthorized people cannot see them.
- These guidelines also apply to personal data that are usually stored electronically but have been printed out for some reason:
- When not required, the paper or files should be kept in a locked drawer, filing cabinet, or environment.
- Employees and contractors should make sure that paper and printouts are not left where unauthorized people could see them, such as in copiers or printers.
- Printouts of personal data should be shredded and disposed of securely when no longer needed.
- When data are stored electronically, they must be protected from unauthorized access, accidental deletion, and malicious hacking attempts.
- Personal data should be protected by strong passwords that are changed regularly and never shared among employees nor contractors.
- If personal data are stored on removable media such as a DVD, CD, or portable drive, they should be kept locked away securely when not used.
- Personal data should only be stored on designated drives and servers and should only be uploaded to approved and secure cloud computing services.
- Servers containing personal data should be situated in a secure location away from general offices and visitor traffic.
- All data should be backed up frequently and securely. Backups should regularly be tested in line with the company’s standard backup procedures.
- Personal data should never be saved directly to laptops, portable drives, tablets, nor smart phones.
- All computers and servers containing personal data should be protected by approved firewall and security software.
3. Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, PerkZilla shall maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually.
- Individuals have the right to access their personal data and any such requests made to PerkZilla shall be dealt with in a timely manner.
4. Lawful purposes
- All data processed by PerkZilla must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
- PerkZilla shall note the appropriate lawful basis in the Register of Systems.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in PerkZilla’s systems.
5. Data minimization
PerkZilla will make sure that personal information are sufficient, pertinent and minimal to what is necessary in relation to the purposes for which they are processed.
- PerkZilla shall take reasonable steps to ensure personal data is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
- The law requires PerkZilla to take reasonable steps to make sure that personal data are kept accurate and up to date.
- The more important it is that the personal data are accurate, the more effort PerkZilla should put into guaranteeing their accuracy.
- It is the responsibility of all employees, contractors, and others who work with personal data to take reasonable steps to keep personal data as accurate and up to date as possible.
- Personal data will be held in as few places as necessary. Company employees and contractors should not create unnecessary additional data sets.
- Company employees and contractors should take every opportunity to make sure that data are updated. For example, by confirming customers’ information when they call.
- PerkZilla will make it easy for data subjects to update the information PerkZilla holds about them. As an example, by using the company website, Internet portal, by email or by phone.
- Personal data should be updated when 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.
- It is the marketing manager’s responsibility to make sure that marketing databases are checked and updated against industry suppression files yearly.
7. Archiving / removal
- To ensure that personal data is kept for no longer than necessary, PerkZilla shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
- The archiving policy shall consider what data should/must be retained, for how long, and why.
- PerkZilla shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, PerkZilla shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website)
10. Providing information
PerkZilla does its best to make sure that individuals are aware that their data are being processed, and that they understand:
- how their personal data are being used
- how to exercise their rights under the law.
Subject access requests
All individuals who are the subjects of personal data held by PerkZilla are entitled to:
- ask what information the company holds about them and why
- ask how to gain access to it
- know how to keep it up to date
- know 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 (SAR).
SARs from individuals should be made by email addressed to the data controller by using the contact information at the bottom of this policy or via live chat support. The data controller can supply a standard request form, although individuals do not have to use it.
The data controller will provide the relevant data within 30 days from receiving the request. The data controller will always verify the identity of anyone making a subject access request before providing them with any information.
The company has a comprehensive privacy notice explaining how data relating to individuals are collected, processed, stored, shared, and protected by the company.
This data protection policy notice is available on request. A current version of this notice is also available on the company’s website.
If you have any questions about data protection policy, please contact us at Privacy@PerkZilla.com or via chat support.