Data protection, security and business continuity policy
Key details
• Policy prepared by: Netfluential IT Department
• Approved by board / management on: 16 March 2023
• Policy became operational on: 16 March 2023
• Next review date: 1 March 2025
Introduction
Netfluential needs 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 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 Netfluential:
• Complies with the UK data protection law and follow good practice as set out by the MRS (Market Research Society)
• 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 Netfluential— 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
People, risks and responsibilities
Policy scope
This policy applies to:
• The head office of Netfluential
• All branches of Netfluential
• All staff and volunteers of Netfluential
• All contractors, suppliers and other people working on behalf of Netfluential
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 Netfluential 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 Netfluential 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 Netfluential meets its legal obligations.
• The data protection officer], 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 Netfluential 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 IT manager, 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.
• The marketing manager is responsible for:
o Approving any data protection statements attached to communications such as emails and letters.
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 should be those who need it for their work.
• Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
• Netfluential will provide training to all employees to help them understand their responsibilities when handling data.
• Employees 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 should request help from their line manager or the 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.
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.
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
• 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 between employees.
• 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.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
• 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 Netfluential 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. The IT manager can explain how to send data to authorised external contacts.
• 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 Netfluential 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 Netfluential 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.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• Netfluential will make it easy for data subjects to update the information Netfluential holds about them. For instance, via the company website.
• Data should 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 Netfluential 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 [email address]. 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, Netfluential 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.
Providing information
Netfluential 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 statement, setting out how data relating to individuals is used by the company.
(This is available on request. A version of this statement is also available here.)
Netlfuential Security and Protection of Data Policy
Version 1.3: December 2023
netfluential is committed to maintaining the highest standards of security in data-protection. This policy sets out the specific measures implemented and regulations to follow for all members of staff.
1. General
1.1. Firewalls must always be used to secure the company’s network(s) connections to the internet.
1.2. Rules and methods governing the firewall must be recorded. All inbound access must be denied except through standard http and http(s) ports. Outbound connections should only be allowed through specified ports necessary for the functioning of key systems.
1.3. Virus-checking software should be installed on all firewalls, servers and workstations and updates installed daily. All systems must be patched against TCP/IP denial of service attacks and different types of email related attacks.
1.4. All server computers should be physically secured in a managed location with 24 hour security.
2. Security management
2.1. All employees should be aware of, and comply with, all protection of data regulations as set out in this policy. Instruction in these regulations will form part of the induction programme of new employees.
2.2. Netfluential has given notification to and, at all times, aims to acts in accordance with, the Data Protection Act.
2.3. The executive Directors shall assume full responsibility for data protection and security compliance.
2.4. The security policy shall be subject to an annual review by the board to ensure that all measures therein are compliant with changes in the data protection and/or take account of significant changes in the technology landscape which may represent a threat to the security of data.
3. Control of access to information
3.1. netfluential premises are secured by warden control and electronic key-card entry. All employees must register with the building security staff and receive a key-card. Key-cards must not be shared under any circumstances.
3.2. Hard copies of sensitive and/or client data must be kept in designated secure storage. Access to these areas will be through permission from Senior Management only.
3.3. All sensitive electronic data must be stored on the appropriate secure system (PPA, dedicated or file servers). Access to these systems will be through secure password.
3.4. Employees requiring access to sensitive and or/client data for project purposes must gain permission from the Directors. Hard copies must be signed out and signed in to ensure that their location is known at all times.
3.5. Hard copies of data should only be maintained for the minimum amount of time necessary for the project and /or to comply with any external regulatory restrictions which may apply. Hard copies of data which have been transferred onto secure electronic systems must be destroyed through shredding before being disposed of.
3.6. Electronic data will be automatically backed up as part of the netfluential disaster recovery systems. All back-up files will be stored on servers at a secure data centre with no external access permitted. Purging of data should be carried our in accordance with any specified client requirements, otherwise this will be done in accordance with guidelines as set out in the Data Protection Act (data should not be stored for any longer than is required to fulfil the purpose for which it was obtained).
4. Access to information by third parties/sub-contractors
4.1. Where third party suppliers are involved in the supply of technical services, it must be determined that only authorised personnel at the relevant data centre have access to physical servers for re-boot or power supply changes only. All interactions with hardware including acquisition or disposal must be subject to documented security routines available for inspection by netfluential.
4.2. There must be no third party access to soft copies of information stored on netfluential systems, except by specific authorised request from technical providers to the Operations Director at netfluential for systems support. Such requests must be initiated by netfluential, and must take place under the full supervision of the Operations Director.
4.3. Any transferral of data to third parties sub-contracted to supply project based services must be specifically authorised by a Director. Before any such transfer, the sub-contractor shall provide netfluential with documented security and data protection policy, which must meet appropriate storage, access and disposal standards.
5. Business continuity
5.1. All critical hardware procured for the purpose of containing data and / or knowledge vital to the continuance of netfluential’s core business must be multiply redundant, with a minimum configuration of RAID 2, and preferably RAID 6.
5.2. All systems containing data will be subject to full weekly, and daily incremental back-ups, to a physical location other than current storage.
5.3. All hardware and key personnel will be covered by an appropriate insurance policy.
5.4. Telecommunication systems, including all critical numbers and extensions, must be configurable such that they can be accessed and utilised from multiple locations in the event of an emergency.
6. Staff recruitment, training and discipline
6.1. References must be obtained from at least two sources for any potential employees before a position is offered. Specific efforts should be made to determine any previous breaches of policy or discipline which may have lead to, or threatened, the security of business critical data.
6.2. Any qualifications claimed should be verified with the appropriate body.
6.3. Employees must sign an employment contract before any employment commences.
6.4. All new employees must be made aware of security policy at netfluential, and the data protection act, as part of their induction programme.
7. Detecting and managing breaches of security
7.1. Comprehensive logs must be kept of all server sessions and access to all other critical systems. Logs must identify the user ID, along with date, time and session length.
7.2. All data-centre servers must have 24 hour security procedures, immediately notifying netfluential if any attempt to gain unauthorised access is detected.
7.3. Any attempt to gain unauthorised access to netfluential systems will result in an immediate change of all password access codes. A full review of all policies, procedures and systems access logs will be undertaken to determine the likely source of any breach. Any employee found to have threatened security through negligence of any of the regulations contained in this document will face disciplinary procedures.
Business Continuity Policy Summary - January 2023
Introduction
Netfluential (“the company” or “Company”) is committed to providing the best possible experience to its customers and the best possible relationships with employees, shareholders and suppliers. To ensure the consistent availability and delivery of its products and services, the company has developed the following business continuity and disaster recovery (BC/DR) policy in support of a comprehensive program for BC, DR and overall business survivability.
The Company, like any other firm, is exposed to potential risks that could disrupt or destroy critical business functions and/or the production and delivery of Company goods and services. Our strategy for continuing business in the event of an incident is to ensure the safety and security of all employees; and to continue critical business functions, production and delivery of products and services from predefined alternative sites.
Purpose and Scope
The purpose of the BC/DR policy is to ensure that all Company business activities can be kept at normal or near-normal performance following an incident that has the potential to disrupt or destroy the Company.
The scope of this policy is the entire Company, its subsidiaries, offices and employees in the UK or abroad.
Statement of Policy
Each department in the Company is responsible for preparing current and comprehensive business continuity plans (BCP) for its operations. Certain departments, such as Information Technology (IT), are also responsible for disaster recovery plans (DRP) to ensure that any damage or disruptions to critical assets can be quickly minimized and that these assets can be restored to normal or near-normal operation as quickly as possible.
When a plan is completed, approved and implemented, each plan will include procedures and support agreements which ensure on-time availability and delivery of required products and services. Each plan must be certified annually with the business continuity policy compliance process through the BC/DR Team.
The company acknowledges that it will use the British Standard, BS 25999, Part 2:2007 as the guidance and structure for its business continuity activities and the ISO/IEC 24762 standard for all comparable disaster recovery activities.
The company recognizes the importance of an active and fully supported BC/DR program to ensure the safety, health and continued availability of employment of its employees and the production and delivery of quality goods and services for customers and other stakeholders. The company requires the commitment of each employee, department and vendor in support of the activities required to protect Company assets, mission and survivability.
Policy Leadership
Lee Eyre is designated as the corporate management liaison responsible for the BC/DR program. Resolution of issues in the development of, or support of, all BC/DR plans and associated activities should first be coordinated with the BC/DR Team and appropriate internal or external organizations before submitting to the corporate management liaison. The issue resolution process is defined in the following section.
Verification of Policy Compliance
BC/DR compliance verification is managed by Lee Eyre with support from other relevant internal departments or staff members. Each plan must define appropriate procedures, staffing, tools and workplace planning activities necessary to meet compliance requirements. Plan templates have been developed to facilitate the plan development process, and these templates shall be used for all plans. Detailed policy compliance verification activities are defined by the BC/DR Team and are included in our full plan designed to form part of any agreement of service.