Data protection policy

Context and overview



Key details

● Policy prepared by: 5th May 2018
● Approved by board / management on: 24th May 2018
● Policy became operational on: 20th May 2018
● Next review date: 20th May 2019


Introduction

WasteAction Resource Efficiency Ltd and Warp It need to gather and use certain information about individuals.

These can include customers, 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 will 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 WasteAction Resource Efficiency Ltd:

● Complies with data protection law and GDPRS 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

The Data Protection Act 1998 describes how organisations — including WasteAction Resource Efficiency Ltd— must collect, handle and store personal information.

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.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection


GDPR

Replaces. Data Protection Directive. Current legislation on 25th May 2018

The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within on the European Union. It addresses the export of personal data outside the EU.

People, risks and responsibilities

Policy scope


This policy applies to:

● The head office of WasteAction Resource Efficiency Ltd
● All staff of Waste Action Resource Efficiency Ltd
● All contractors, suppliers and other people working on behalf of Waste Action Resource Efficiency Ltd

It applies to all data that the company holds relating to identifiable individuals. This includes, for the company:

● Full names of Individuals
● Work postal addresses
● Work Email addresses
● Work Telephone numbers
● plus any other information relating to individuals that have come to our attention via review or marketing calls and that is documented in the CRM currently hubspot



Responsibilities

Everyone who works for or with WasteAction Resource Efficiency Ltd has 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 Directors is ultimately responsible for ensuring that Waste Action Resource Efficiency meets its legal obligations.
● The Data protection Officer, Alexandra O’Connor, is responsible for:
o Keeping the board updated about data protection responsibilities, risks and issues.
o Reviewing all data protection procedures and related policies, in line with an agreed schedule.
o Arranging data protection training and advice for the people covered by this policy.
o Handling data protection questions from staff and anyone else covered by this policy.
o Dealing with requests from individuals to see the data Waste Action Resource Efficiency Ltd holds about them (also called ‘subject access requests’).
o Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
● The software development company, Eightlegged.com, is responsible for:
o Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
o Performing regular checks and scans to ensure security hardware and software is functioning properly.
o Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
o Considering any issues that relate to the running of the system and usability of the site.
● The server management company, Rapid Switch an Iomart company, is responsible for:
o The security and management of the server where Warp It data is help for WasteAction Resource Efficiency Ltd
o Take a look at their website here
● The Marketing Manager, Daniel O’Connor, is responsible for:
o Approving any data protection statements attached to communications such as emails and letters.
o Compliancy to any bought in lists.
o Addressing any data protection queries from journalists or media outlets like newspapers.
o Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General staff guidelines

● The only people able to access data covered by this policy are those who need it for their work.
● Data is not be shared informally. All data is accessed only by those employees who need it to maintain the running of the site.
● WasteAction Resource Efficiency Ltd provides training to all employees to help them understand their responsibilities when handling data.
● Employees will 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 will not be disclosed to unauthorised people, either within the company or externally.
● Data will be reviewed and updated if it is found to be out of date. If no longer required, it will be deleted and disposed of.
● Employees will request help of their data protection officer 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.

Data is will not be stored on paper.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

● The WasteAction Resource Efficiency Ltd It offices are not customer facing and as such do not have unauthorised people entering of leaving at will, however if in the rare circumstances that an unauthorised person does enter, a workperson for example then all paper data should be removed from sight.
● 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 is protected by strong passwords on the individual computers, that are changed regularly and never shared between employees.
● In the unlikely event data needs to be stored on removable media (like a CD or DVD), these are be kept locked away securely when not being used.
● Data will only be stored on designated drives and servers, and is only uploaded to an approved cloud computing services that is GDPRS compliant - currently hubspot.
● Servers containing personal data should be sited in a secure location, away from general office space. (See further detail below)
● Data is be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures. (see below)
● Data is 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.

Hosting Provider & Data Location

The hosting provider is WasteAction Resource Efficiency Ltd.

WasteAction Resource Efficiency Ltd have servers in a large DC which is securely fenced, with CCTV cameras to monitor the premises. Inside we have a secure data floor with multiple zones for hosting rack mounted or ATX boxes. The site has many fail systems e.g Multiple generators, different connections into/out of the DC.

The primary data being stored and backed up in Maidenhead, KENT, UK.

Up to a 10GB connection of network bandwidth is available. Scalability is Extremely Large provided for by additional computing power or storage.

Data Access, Security, Log in, Segregation & Encryption

Personal user data includes work address, email and telephone number. Passwords are encrypted. Records of user trades of surplus items are also stored. This data is stored only and is not shared with any third parties.

Data is stored in a dedicated environment. RapidSwitch, a trading name of Iomart Hosting Ltd and Eightlegged.com have access to the infrastructure, hardware, software and data.

The primary data encrypted using TDE & Hash User sign on via Secure login over https.

Database and the login routines are encrypted to SHA256 standard.

Hosting Facility Security

The Data Centre has a secure fence around the premises with a gated entrance only accessible to staff. Visitors must provide photographic ID when visiting and will be recorded on our database. Only technicians have access to the Data Floor. Security of the hosting facility is reviewed every 6 months for ISO accreditation.

Customer data is never transferred to laptop, netbook or other portable devices either as part of the normal operation of the service or as part of the development or maintenance of the service.

The relevant accreditations for the hosting environment - i.e. the physical security and the security around systems pertaining to the environment is ISO 27001 and 9001.

Business Continuity & Disaster Recovery

Please see below for business continuity & disaster recovery options available as part of the standard services.

WasteAction Reuse Portal (Warp It) Backup Policy
Introduction

Warp It by WasteAction Resource Efficiency Ltd is committed to managing its customers records including regular backups and archives.

Definitions - To back up data is to copy to another medium or storage so that, if the active data is lost, it can be recovered in a recent if not completely current version. Backup is primarily intended for disaster recovery, and the assumption is that in most cases the backed-up data will not be read.

Policy

The objectives of this Policy are to: ● identify and store records of transactions on the Warp It exchange system.
● keep the records safe and secure
● take all necessary steps to ensure the safety and security
● describe access arrangements

Back up management

The files which are backed up are

● All company portal transactions
● Uploads of items/ resources (photos etc)
● User transactions within and between organisations
● All transactions details including the financial and environmental reporting values.
● Log in records
● Company account settings
● User account settings

Where data contains personal information- for example the user account area, there is only one master file and one backup copy. This is for security reasons.

Central backup of data

WasteAction Resource Efficiency Ltd maintains backups of the data specified above. Backups of each customer portal , all data and of all items, users and transaction will be taken everyday.

Access Policy

The administrator for each portal can download transaction data at any time in the settings dashboard. Administrators can view all transaction details from this tool.

Access to additional data on customer portals can be made by emailing dataprotection@warp-it.co.uk with 14 days notice and specific data required. Data use

Data use

Personal data is of no value to WasteAction Resource Efficiency Ltd 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 must ensure the screens of their computers are always locked when left unattended.
● Personal customer data will not be shared informally. In particular, it will in most cases, not be sent by email, unless to comply with the running of the contract. However prospect data will be shared via email with compliant 3rd parties.
● Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
● Customer Personal data will never be transferred outside of the European Economic Area.
● Employees will 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 Waste Action Resource Efficiency Ltd to take reasonable steps to ensure data is kept accurate and up to date.

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 will not create any unnecessary additional data sets.
● Staff will take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
● Waste Action Resource Efficiency Ltd will make it easy for data subjects to update the information Waste Action Resource Efficiency Ltd holds about them. For instance, via the company website.
● Data will 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.
● It is the marketing manager’s responsibility to 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 Waste Action Resource Efficiency 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 dataprotection@warp-it.co.uk. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.

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, Waste Action Resource Efficiency 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.

To complete transactions with third parties, in this case, other approved Warp It institutions for the express purpose of reusing surplus assets, we will share personal data. Notably this will only include collected data of Full Name and works email address

We also collect transactional data for reporting. This will not include any personal data and is just the KPI gathered within the processes of the system. This data may be used by WasteAction Resource Efficiency Ltd and other third parties for promotion, reporting and press releases. There is no licence agreement needed for this kind of data sharing. If you would like to know more about the data included then please refer to https://www.warp-it.co.uk/report-guide

Providing information

WasteAction Resource Efficiency 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 policy, setting out how data relating to individuals is used by the company.

This is available on request. And a copy of this policy is also available on the company’s website at https://www.warp-it.co.uk/policy

Data Breach resolutions

Common Issues/ Questions

Identifying and monitoring unauthorised users and unapproved behaviour from approved users.

Definition

Authorised users are those who have been approved by the administrator in the customer organisation. Unauthorised users are those who have not been approved by any admin and are accessing the system illegally and outside of the Warp It T&C’s.

Please note: In some cases there could be attacks by authorised users (disgruntled staff for example).

Collected data

The following collected data is the limit of our data collection for our customers. We do not collect or require any sensitive data.

● work email address
● work address
● work telephone number
● encrypted password

Passwords are stored, but they are protected by a cryptographic hash function.

Records of user trades of surplus items are also stored. This data is stored only and is not shared in anyway.

Physical protection

The hosting location is Maidenhead, KENT, UK . The servers are stored in a large Data Centre which is securely fenced, with CCTV cameras to monitor the premises. Inside we have a secure data floor with multiple zones for hosting rack mounted or ATX boxes.

The Data Centre has a secure fence around the premises with a gated entrance only accessible to staff. Visitors must provide photographic ID when visiting and will be recorded on our database. Only technicians have access to the Data Floor. Security of the hosting facility is reviewed every 6 months for ISO accreditation.

Customer data is never transferred to laptop, netbook or other portable devices either as part of the normal operation of the service or as part of the development or maintenance of the service.

The relevant accreditations for the hosting environment - i.e. the physical security and the security around systems pertaining to the environment is ISO 27001 and 9001. These certifications are predominantly used in the UK but are an international standard.

Unauthorised access; What do we monitor for?

Networks and computers are monitored and usage logged. Logs are kept secure and are only available to personnel authorised by Warp It and will only be kept as long as necessary in line with current data protection guidelines. As of May 5th 2018 we deem it necessary to retain customer data within the Warp It portal for up to 18 months. This means there is no loss of record data or transaction report data if either the customer returns to their subscription within 1 year or there is an issue that needs to be resolved. After this time the data regarding the individual will be removed and replaced by non identifying code thus retaining the transaction data.

Warp It and our Software Partner Eightlegged.com networks and access records are monitored and logged for all lawful purposes including: -

● Ensuring use is authorised
● Management of systems
● Protecting against unauthorised access
● Verifying security procedures
● System and operational security
● Compliance with Warp It terms and conditions
● Detection and prevention of crime

How do we know when unauthorised access happens?

● Logs for all hardware, physical security, applications and databases are collected centrally and monitored for unusual behaviour.
● All events that fall outside of the 'normal' threshold are emailed to the on call engineer.
● Short term auto banning systems are in place for user accounts and IP addresses that perform unusual activity.
● There is an escalation process in place for all urgent incidents

The Data Protection Officer (from Warp It and/or Eightlegged.com) may do so through any unusual activity and monitoring of logs. Events are monitored and alerts raised when unusual activity occurs.

System administrators may do so by observing suspicious system behaviour. Any member of the Warp It community may identify a potential security incident though external complaint/notification, or other knowledge of impermissible use or disclosure of Data.

The aim of our intruder detection system is to actively monitor for unusual or suspicious behaviour. Warp It monitor this in several ways, by automated systems that track and analyse behaviours patterns in logs or system usage. Remediation can range from temporarily ban users and IP ranges based on suspicious activity, and by hands on intervention and analysis to higher level events. Objectives of the intruder detection system are

● Actively search for signs of unauthorised intrusion
● Prevent or detect the confidentiality of Warp It data on the network
● Preserve the integrity of Warp It data on the network
● Prevent unauthorised use of Warp It systems
● Keep hosts and network resources available to authorised users
● Increase security by detecting weaknesses in systems and network design early

How will we notify you of a security breach?

Our internal security breach process is summarised below.

The Warp It engineer from eightlegged.com responsible for support of the system is expected to:

● Report the attack to Alexandra O’Connor Data Protection and Daniel O’Connor CEO at Warp It.
● Block or prevent escalation of the attack
● Investigation of the incident and preservation of evidence
● Daniel O’Connor (Warp It) to report incident to customer within 24 hours via phone (or some other method at the customers request)
● Repair the resultant damage to the system

Any suspected intrusions, suspicious activity, or unexplained erratic behaviour will be reported to the customer within 24 hours by a communication method of their choice.

Customers administrators are also expected to report any suspicious activity as soon as it is recognised.

Who will have access to your data?

Data is stored in a dedicated environment. RapidSwitch, a trading name of iomart Hosting Ltd (hosting company) and Eightlegged.com (software developer) have access to the infrastructure, hardware, software and data.

Staff within WasteAction Resource Efficiency and Eightlegged.com in line with our privacy policy at www.warp-it.co.uk/policy

The administrator in the institution can download transaction data at any time in the settings dashboard. Administrators can view all transaction details from this tool.

Access to additional data on customer portals can be made by emailing dataprotection@warp-it.co.uk with 14 days notice and specific data required.