GDPR and
Data Protection

Iberia Impex is committed to processing and storing data in accordance with its

responsibilities under the General Data Protection Regulations (GDPR) and Data Protection Act 1998.

 

Article 5 of the GDPR requires that personal data shall be:

a. “processed lawfully, fairly and in a transparent manner in relation to individuals;

b. 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;

c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

d. 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;

e. 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 insofar 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

f. 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.”

 

General Provisions

a. This policy applies to all personal data processed and stored by Iberia Impex.

b. This policy shall be reviewed at least annually.

c. Iberia Impex shall register with the Information Commissioner’s Office as an organisation that processes and stores personal data.

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Lawful, fair and transparent processing

a. To ensure its processing of data is lawful, fair and transparent, Iberia Impex shall maintain a Register of Data.

b. The Register of Data shall be reviewed at least annually to ensure all data is in compliance with GDPR, necessary to store and that we have an agreed GDPR statement from the client.

c. Individuals have the right to access their stored personal data and any such requests made to Iberia Impex shall be dealt with in a timely manner.

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Lawful purposes

a. All data processed and stored by Iberia Impex must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task, ongoing service, current client, current partner or legitimate interests.

b. The Charity shall note the appropriate lawful basis in the Register of Data.

c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

d. 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 Iberia Impex registers.

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Data minimisation

a. Iberia Impex shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

b. Iberia Impex will only store data with consent, for ongoing clients, current clients, current partners, clients currently using their services or clients that have used their service within the last 7 working days. Clients that have used their service within the last 7 working days will have their data stored for those 7 days for insurance purposes.

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Accuracy

a. Iberia Impex shall take reasonable steps to ensure personal data is accurate.

b. 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.

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Archiving / removal

a. To ensure that personal data is kept for no longer than necessary, Iberia Impex shall put in place an archiving policy for each area in which personal data is processed and review this process annually.

b. The archiving policy shall consider what data should/must be retained, for how long, and why.

c. Iberia Impex shall request consent to store personal data at least annually as required by GDPR.

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Security

a. Iberia Impex shall ensure that personal data is stored securely using modern software that is kept-up-to-date.

b. 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.

c. When personal data is deleted this should be done safely such that the data is irrecoverable.

d. Appropriate back-up and disaster recovery solutions shall be in place.

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Handling of personal/sensitive information

Iberia Impex will, through appropriate management and the use of strict criteria and controls: -

• Observe fully conditions regarding the fair collection and use of personal information;

• Meet its legal obligations to specify the purpose for which information is used;

• Collect and process appropriate information and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements;

• Ensure the quality of information used;

• Apply strict checks to determine the length of time information is held;

• Take appropriate technical and organisational security measures to safeguard personal information;

• Ensure that personal information is not transferred abroad without suitable safeguards;

• Ensure that the rights of people about whom the information is held can be fully exercised. These include:

-the right to be informed that processing is being undertaken;

-the right of access to one’s personal information within the statutory 40 days The right to prevent processing in certain circumstances;

-the right to correct, rectify, block or erase information regarded as wrong information.

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In addition, Iberia Impex will ensure that:

• There is someone with specific responsibility for data protection in the business;

• Everyone managing and handling personal information understands that they are contractually responsible for following good data protection practice;

• Everyone managing and handling personal information is appropriately trained to do so;

• Everyone managing and handling personal information is appropriately supervised;

• Anyone wanting to make enquiries about handling personal information, whether a member of staff or a member of the public, knows what to do;

• Queries about handling personal information are promptly and courteously dealt with;

• Methods of handling personal information are regularly assessed and evaluated;

• Performance with handling personal information is regularly assessed and evaluated;

• Data sharing is carried out under a written agreement, setting out the scope and limits of the sharing. Any disclosure of personal data will be in compliance with approved procedures.

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All employees and partners are to be made fully aware of this policy and of their duties and responsibilities under the Act.

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All of the above will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure and in particular will ensure that:-

• Paper files and other records or documents containing personal/sensitive data are kept in a secure environment;

• Personal data held on computers and computer systems is protected by the use of secure passwords, which where possible have forced changes periodically;

• Individual passwords should be such that they are not easily compromised.

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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 unauthorized 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 unauthorized people could see them, like on a printer.

• Data printouts should be shredded and disposed of securely when no longer required.

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Notification to the Information Commissioner

The Information Commissioner maintains a public register of data controllers. Iberia Impex is registered as such. The Data Protection Act 1998 requires every data controller who is processing personal data, to notify and renew their notification, on an annual basis. Failure to do so is a criminal offence. 

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Breach

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, Iberia Impex shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO and client the personal data belongs to in accordance to the law.