Introduction

GERS USA needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees, and other people the organization 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.

Why this policy exists

This data protection policy ensures that GERS USA:

• Complies with data protection laws and follows good practices

• 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 United States Data Protection law describes how organizations — including GERS USA— 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:

• 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 United States of America, unless that country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope

This policy applies to:

• The head office of GERS USA

• All branches of GERS USA

• All staff and volunteers of GERS USA

• All contractors, suppliers and other people working on behalf of GERS USA

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

• …plus any other information relating to individuals

Data protection risks

This policy helps to protect Gersusa from some 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 GERS USA 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 GERS USA meets its legal obligations.

• The , data protection officer is responsible for:

• Keeping the board updated about data protection responsibilities, risks and issues.

• 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 Gersusa holds about them (also called ‘subject access requests’).

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

• The , IT Manager, is responsible for:

• 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.

• The Marketing Manager, is responsible for:

• 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.