Google Rating
5.0
Based on 22 reviews
Google Rating
5.0
Based on 22 reviews

1.    Introduction

This Policy sets out the obligations of Vine Digital Ireland, regarding data protection and the rights of customers, business contacts and website visitors (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).
The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

2.    The Data Protection Principles

This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:

2.1    Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
2.2    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.
2.3    Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
2.4    Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.
2.5    Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is 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 the data subject.
2.6    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.

3.    The Rights of Data Subjects

The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):

3.1    The right to be informed (Part 12).
3.2    The right of access (Part 13);
3.3    The right to rectification (Part 14);
3.4    The right to erasure (also known as the ‘right to be forgotten’) (Part 15);
3.5    The right to restrict processing (Part 16);
3.6    The right to data portability (Part 17);
3.7    The right to object (Part 18).

4.    Lawful, Fair, and Transparent Data Processing

4.1    The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:

4.1.1    The data subject has given consent to the processing of their personal data for one or more specific purposes;
4.1.2    The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;
4.1.3    The processing is necessary for compliance with a legal obligation to which the data controller is subject;
4.1.4    The processing is necessary to protect the vital interests of the data subject or of another natural person;
4.1.5    The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or
4.1.6    The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

4.2    If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:

4.2.1    The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);
4.2.2    The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);
4.2.3    The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
4.2.4    The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;
4.2.5    The processing relates to personal data which is clearly made public by the data subject;
4.2.6    The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;
4.2.7    The processing is necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;
4.2.8    The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;
4.2.9    The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or
4.2.10    The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

5.    Specified, Explicit, and Legitimate Purposes

5.1    The Company collects and processes the personal data set out in Part 21 of this Policy. This includes:

•    Personal data collected directly from data subjects; and
•    Personal data obtained from third parties.

5.2    The Company only collects, processes, and holds personal data for the specific purposes set out in Part 21 of this Policy (or for other purposes expressly permitted by the GDPR).
5.3    Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 12 for more information on keeping data subjects informed.

6.    Adequate, Relevant, and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 5, above, and as set out in Part 21, below.

7.    Accuracy of Data and Keeping Data Up-to-Date

7.1    The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 14, below.
7.2    The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

8.    Data Retention

8.1    The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.
8.2    When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
8.3    For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.

9.    Secure Processing

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 22 to 27 of this Policy.

10.    Accountability and Record-Keeping

10.1    The Company’s Data Protection matters are dealt with the Operations Director.
10.2    The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

10.2.1    The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;
10.2.2    The purposes for which the Company collects, holds, and processes personal data;
10.2.3    Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;
10.2.4    Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
10.2.5    Details of how long personal data will be retained by the Company (please refer to the Company’s Data Retention Policy); and
10.2.6    Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

11.    Data Protection Impact Assessments

11.1    The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data which involve the use of new technologies and the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the GDPR.
11.2    Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:

11.2.1    The type(s) of personal data that will be collected, held, and processed;
11.2.2    The purpose(s) for which personal data is to be used;
11.2.3    The Company’s objectives;
11.2.4    How personal data is to be used;
11.2.5    The parties (internal and/or external) who are to be consulted;
11.2.6    The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
11.2.7    Risks posed to data subjects;
11.2.8    Risks posed both within and to the Company; and
11.2.9    Proposed measures to minimise and handle identified risks.

12.    Keeping Data Subjects Informed

12.1    The Company shall provide the information set out in Part 12.2 to every data subject:

12.1.1    Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and
12.1.2    Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:

a)    if the personal data is used to communicate with the data subject, when the first communication is made; or
b)    if the personal data is to be transferred to another party, before that transfer is made; or
c)    as soon as reasonably possible and in any event not more than one month after the personal data is obtained.

12.2    The following information shall be provided:

12.2.1    Details of the Company including, but not limited to, the identity of its Data Protection Officer;
12.2.2    The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;
12.2.3    Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
12.2.4    Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
12.2.5    Where the personal data is to be transferred to one or more third parties, details of those parties;
12.2.6    Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 28 of this Policy for further details);
12.2.7    Details of data retention;
12.2.8    Details of the data subject’s rights under the GDPR;
12.2.9    Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
12.2.10    Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the GDPR);
12.2.11    Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and

13.    Data Subject Access

13.1    Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.
13.2    Employees wishing to make a SAR should do using a Subject Access Request Form, sending the form to the Company’s Operations Director via email: hello@vinedigital.ie.
13.3    Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.
13.4    All SARs received shall be handled by the Company’s Operations Director.
13.5    The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

14.    Rectification of Personal Data

14.1    Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.
14.2    The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
14.3    In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

15.    Erasure of Personal Data

15.1    Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

15.1.1    It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
15.1.2    The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
15.1.3    The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning the right to object);
15.1.4    The personal data has been processed unlawfully;
15.1.5    The personal data needs to be erased in order for the Company to comply with a particular legal obligation;

15.2    Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
15.3    In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

16.    Restriction of Personal Data Processing

16.1    Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.
16.2    In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

17. ()
18.    Objections to Personal Data Processing

18.1    Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling), [and processing for scientific and/or historical research and statistics purposes].
18.2    Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.
18.3    Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.
19.  ()
20.  ()

21.    Personal Data Collected, Held, and Processed

The following personal data is collected, held, and processed by the Company (for details of data retention, please refer to the Company’s Data Retention Policy):

Type of Data – Purpose of Data
Name See paragraphs 4.1.2, 4.1.3 and 4.1.6
Postal Address See paragraphs 4.1.2, 4.1.3 and 4.1.6
Email address See paragraphs 4.1.2, 4.1.3 and 4.1.6
Telephone Number See paragraphs 4.1.2, 4.1.3 and 4.1.6
Voice Recording See paragraphs 4.1.2, 4.1.3 and 4.1.6
File notes See paragraphs 4.1.2, 4.1.3 and 4.1.6
Emails See paragraphs 4.1.2, 4.1.3 and 4.1.6

22.    Data Security – Transferring Personal Data and Communications

The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

22.1    All emails containing personal data must be marked “confidential”;
22.2    Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
22.3    Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
22.4    Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;
22.5    Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
22.6    Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient; and
22.7    All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.

23.    Data Security – Storage

The Company shall ensure that the following measures are taken with respect to the storage of personal data:

23.1    All electronic copies of personal data should be stored securely using passwords;
23.2    All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;
23.3    All personal data stored electronically should be backed up daily with backups stored onsite and offsite. All backups should be encrypted;
23.4    No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and
23.5    No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).

24.    Data Security – Disposal

When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.

25.    Data Security – Use of Personal Data

The Company shall ensure that the following measures are taken with respect to the use of personal data:

25.1    No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from the Operations Director;
25.2    No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of the Operations Director;
25.3    Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;
25.4    If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and
25.5    Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the Operations Director to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.

26.    Data Security – IT Security

The Company shall ensure that the following measures are taken with respect to IT and information security:

26.1    All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. All software used by the Company is designed to require such passwords;
26.2    Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
26.3    All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates as soon as reasonably and practically possible, unless there are valid technical reasons not to do so; and
26.4    No software may be installed on any Company-owned computer or device without the prior approval of the Operations Director.

27.    Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

27.1    All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy;
27.2    Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
27.3    All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
27.4    All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
27.5    All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
27.6    Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
27.7    All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;
27.8    The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
27.9    All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;
27.10    All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the GDPR; and
27.11    Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

28.    Transferring Personal Data to a Country Outside the EEA

28.1    The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.
28.2    The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:

28.2.1    The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
28.2.2    The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
28.2.3    The transfer is made with the informed consent of the relevant data subject(s);
28.2.4    The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
28.2.5    The transfer is necessary for important public interest reasons;
28.2.6    The transfer is necessary for the conduct of legal claims;
28.2.7    The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
28.2.8    The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

29.    Data Breach Notification

29.1    All personal data breaches must be reported immediately to the Company’s Operations Director.
29.2    If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Operations Director must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
29.3    In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of data subjects, the Operations Director must ensure that all affected data subjects are informed of the breach directly and without undue delay.
29.4    Data breach notifications shall include the following information:

29.4.1    The categories and approximate number of data subjects concerned;
29.4.2    The categories and approximate number of personal data records concerned;
29.4.3    The name and contact details of the Company’s Operations Director (or other contact point where more information can be obtained);
29.4.4    The likely consequences of the breach;
29.4.5    Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

30.    Implementation of Policy

This Policy shall be deemed effective as of 15/05/2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

1. Introduction

This Policy sets out the obligations of Vine Digital Ireland, regarding retention of personal data collected, held, and processed by the Company in accordance with EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

The GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation.

Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).

In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:

a)    Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);
b)    When the data subject withdraws their consent;
c)    When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;
d)    When the personal data is processed unlawfully (i.e. in breach of the GDPR);
e)    When the personal data has to be erased to comply with a legal obligation; or
f)    Where the personal data is processed for the provision of information society services to a child.

This Policy sets out the type(s) of personal data held by the Company for identification, procurement, sales and marketing purposes, the period(s) for which that personal data is to be retained, the criteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of.
For further information on other aspects of data protection and compliance with the GDPR, please refer to the Company’s Data Protection Policy.

2.    Aims and Objectives

2.1    The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this Policy aims to ensure that the Company complies fully with its obligations and the rights of data subjects under the GDPR.
2.2    In addition to safeguarding the rights of data subjects under the GDPR, by ensuring that excessive amounts of data are not retained by the Company, this Policy also aims to improve the speed and efficiency of managing data.

3.    Scope

3.1    This Policy applies to all personal data held by the Company and by third-party data processors processing personal data on the Company’s behalf.
3.2    Personal data, as held by the Company is stored in the following ways and in the following locations:

a)    The Company’s servers, located in Singapore.
b)    Laptop computers and other mobile devices provided by the Company to its employees;]
c)    Cloud servers via Google located in the EU and USA

4.    Data Subject Rights and Data Integrity

All personal data held by the Company is held in accordance with the requirements of the GDPR and data subjects’ rights hereunder, as set out in the Company’s Data Protection Policy.

4.1    Data subjects are kept fully informed of their rights, of what personal data the Company holds about them, how that personal data is used as set out in the Company’s Data Protection Policy, and how long the Company will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined).
4.2    Data subjects are given control over their personal data held by the Company including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the right to restrict the Company’s use of their personal data, the right to data portability, and further rights relating to automated decision-making and profiling.

5.    Technical and Organisational Data Security Measures

5.1    The following technical measures are in place within the Company to protect the security of personal data. Please refer to Parts 22 to 26 of the Company’s Data Protection Policy for further details:

a)    All emails containing personal data must be encrypted;
b)    All emails containing personal data must be marked “confidential”;
c)    Personal data may only be transmitted over secure networks;
d)    Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;
e)    Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;
f)    Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;
g)    Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient;
h)    All personal data transferred physically should be transferred in a suitable container marked “confidential”;
i)    No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from the Operations Director.
j)    All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;
k)    No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation;
l)    Personal data must be handled with care at all times and should not be left unattended or on view;
m)    Computers used to view personal data must always be locked before being left unattended;
n)    No personal data should be stored on any mobile device, whether such device belongs to the Company or otherwise without the formal written approval of the Operations Director and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary;
o)    No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the GDPR;]
p)    All personal data stored electronically should be backed up daily with backups stored onsite and offsite. All backups should be encrypted;
q)    All electronic copies of personal data should be stored securely using passwords and encryption;
r)    All passwords used to protect personal data should be changed regularly and should must be secure;
s)    Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
t)    All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;
u)    No software may be installed on any Company-owned computer or device without approval; and
v)    Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the Operations Director to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.

5.2    The following organisational measures are in place within the Company to protect the security of personal data. Please refer to Company’s Data Protection Policy for further details:

a)    All employees and other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under the Company’s Data Protection Policy;
b)    Only employees and other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company;
c)    All employees and other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
d)    All employees and other parties working on behalf of the Company handling personal data will be appropriately supervised;
e)    All employees and other parties working on behalf of the Company handling personal data should exercise care and caution when discussing any work relating to personal data at all times;
f)    Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
g)    The performance of those employees and other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
h)    All employees and other parties working on behalf of the Company handling personal data will be bound by contract to comply with the GDPR and the Company’s Data Protection Policy;
i)    All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of the GDPR and the Company’s Data Protection Policy;
j)    Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under the GDPR and/or the Company’s Data Protection Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

6.    Data Disposal

Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:

6.1    Personal data stored electronically (including any and all backups thereof) shall be deleted securely;
6.2    Special category personal data stored electronically (including any and all backups thereof) shall be deleted securely;
6.3    Personal data stored in hardcopy form shall be shredded to at least cross cut standard and recycled;
6.4    Special category personal data stored in hardcopy form shall be shredded to at least cross cut standard and recycled.

7.    Data Retention

7.1    As stated above, and as required by law, the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.
7.2    Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below.
7.3    When establishing and/or reviewing retention periods, the following shall be taken into account:

a)    The objectives and requirements of the Company;
b)    The type of personal data in question;
c)    The purpose(s) for which the data in question is collected, held, and processed;
d)    The Company’s legal basis for collecting, holding, and processing that data;
e)    The category or categories of data subject to whom the data relates.

7.4    If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.
7.5    Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).

Data Ref. Type of Data Purpose of Data Review Period Retention Period or Criteria Comments
RECRUITMENT:Candidates; unsuccessful; successful; interviewed; Unsolicited Job applications Name;Address;

Phone number;

Email;

CV;

Selection criteria; Application forms;

Interview rating;

To contactTo Skill code

To place in suitable job role

Reviewed 3 months before end of retention period or when candidate is put forward for an interview or contacted about new roles 6 months – this is the period of time during which a discrimination claim could be brought against our organisation Personal data will be updated if the data subject is a suitable candidate for available roles and would like to be put forward for the role, we will confirm that the data we hold on them is up to date before they are put forward to the role.If we want to keep CVs on file longer than 6 months (e.g. for future opportunities, then we’ll ask consent from applicants, incl update of info when needed).

Disposal by Confidential shredding

STAFF: e.g. Applications; Qualifications; References; Recruitment; Job specs.; Work contract; Records of staff training;Copy of utility bill;

Copy of driving licence;

Working Visa (if required);

Bank details;

Reviews;

Next-of-kin contact details;

Sikness/medical records;

Timesheets;

Parental leave;

Force Majeure leave;

Carers leave;

Disciplinary records;

Etc.

To confirm ability to drive;Proof of residency;

Has the correct visa to work in the country;

To process Payroll

To contact next-of-kin in case of emergency

To comply with employment laws

On each new placement General: Retain for duration of employment plus 7 years (6 years in which to take a claim against the Company, plus 1 year for proceedings to be served on the Company)Parental leave Must be kept for 8 years (Parental Leave Act 1998)

Carers leave Must be kept for 8 years (Carer’s Leave Act 2001)

Accidents records – 10 years

Working hours and related information – 3 years

Next-of-kin – reviewed and updated every 2 years

When any candidate is placed in permanent or contract role, proof is required that the candidate has the right to work in the country and we have their account information to allow our finance department to make required payments.Disposal by Confidential shredding
CLIENTS Company Name;Contact Name;

Job Role;

Phone Number;

Email; Address;

to fulfill placement opportunities within the business Reviewed on each contact to client,or with info found on the public domain 7 years after ending business agreements Disposal by Confidential shredding
FINANCIAL RECORDS Audited accounts;Payroll and taxation;

Invoices/

receipts

In case of audit/refunds by Revenue Reviewed as and when required 6 years Revenue Commissioners requirement: Min. 6 years after the end of the tax year. Records must be made available for inspection by authorised officers of the Revenue Commissioners or of the Dept. of Social Protection.Disposal by Confidential shredding

8.    Roles and Responsibilities

8.1    The Company’s Data Protection matters are dealt with the Operations Director.
8.2    The Operations Director shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other Data Protection-related policies (including, but not limited to, its Data Protection Policy), and with the GDPR and other applicable data protection legislation.
8.3    The Operations Director shall be directly responsible for ensuring compliance with the above data retention periods throughout the Company.
8.4    Any questions regarding this Policy, the retention of personal data, or any other aspect of GDPR compliance should be referred to the Operations Director.

9.    Implementation of Policy

This Policy shall be deemed effective as of 10/05/2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

1. Introduction

This document sets out the measures to be taken by all employees of Vine Digital Ireland Ltd. (the “Company”) and by the Company as a whole in order to protect data (electronic and otherwise) collected, held, and processed by the Company, and to protect the Company’s computer systems, devices, infrastructure, computing environment, and any and all other relevant equipment (collectively, “IT Systems”) from damage and threats whether internal, external, deliberate, or accidental.

For the purposes of this Policy, “data” shall refer to the following type(s) of data:

Personal Data; For the purposes of this Policy, “personal data” shall carry the meaning defined in Article 4 of EU Regulation 2016/679 General Data Protection Regulation (“GDPR”): any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

2. Key Principles

2.1           All IT Systems and data are to be protected against unauthorised access.

2.2           All IT Systems and data are to be used only in compliance with relevant Company Policies.

2.3           All personal data must be used only in compliance with the GDPR and the Company’s Data Protection Policy.

2.4           All employees of the Company and any and all third parties authorised to use the IT Systems and data collected, held, and processed by the Company including, but not limited to, contractors and sub-contractors (collectively, “Users”), must ensure that they are familiar with this Policy and must adhere to and comply with it at all times.

2.5           All line managers must ensure that all Users under their control and direction must adhere to and comply with this Policy at all times as required under paragraph 2.4.

2.6           All data must be managed securely in compliance with all relevant parts of the GDPR and all other laws governing data protection whether now or in the future in force.

2.7           All data must be classified appropriately (including, but not limited to, personal data, sensitive personal data, and confidential information). All data so classified must be handled appropriately in accordance with its classification.

2.8           All data, whether stored on IT Systems or in hardcopy format, shall be available only to those Users with a legitimate need for access.

2.9           All data, whether stored on IT Systems or in hardcopy format, shall be protected against unauthorised access and/or processing.

2.10        All data, whether stored on IT Systems or in hardcopy format, shall be protected against loss and/or corruption.

2.11        All IT Systems are to be installed, maintained, serviced, repaired, and upgraded by The Company (the “IT Department”) or by such third party/parties as the IT Department may from time to time authorise.

2.12        The responsibility for the security and integrity of all IT Systems and the data stored thereon (including, but not limited to, the security, integrity, and confidentiality of that data) lies with the IT Department unless expressly stated otherwise.

2.13        The responsibility for the security and integrity of data that is not stored on the IT Systems lies with the Operations Director, AND/OR the IT Department.

2.14        All breaches of security pertaining to the IT Systems or any data stored thereon shall be reported and subsequently investigated by the IT Department.

2.15        All breaches of security pertaining to data that is not stored on the IT Systems shall be reported and subsequently investigated by the Operations Director, AND/OR the IT Department. Any breach which is either known or suspected to involve personal data shall be reported to the Operations Director.

2.16        All Users must report any and all security concerns relating to the IT Systems or to the data stored thereon immediately to the IT Department. If any such concerns relate in any way to personal data, such concerns must also instead be reported to the Operations Director.

2.17        All Users must report any and all security concerns relating to data that is not stored on the IT Systems immediately to the IT Department. If any such concerns relate in any way to personal data, such concerns must instead be reported to the the Operations Director.

3. Department Responsibilities

3.1           The IT Manager shall be responsible for the following:

  1. ensuring that all IT Systems are assessed and deemed suitable for compliance with the Company’s security requirements;
  2. ensuring that IT security standards within the Company are effectively implemented and regularly reviewed, working in consultation with the Company’s senior management, and reporting the outcome of such reviews to the Company’s senior management;
  3. ensuring that all Users are kept aware of the IT-related requirements of this Policy and of all related legislation, regulations, and other relevant rules whether now or in the future in force including, but not limited to, the GDPR 2018 and the Criminal Damage Act, 1991.

3.2           The Operations Director shall be responsible for the following:

  1. ensuring that all other data processing systems and methods are assessed and deemed suitable for compliance with the Company’s security requirements;
  2. ensuring that data security standards within the Company are effectively implemented and regularly reviewed, working in consultation with the Company’s senior management and reporting the outcome of such reviews to the Company’s senior management;
  3. ensuring that all Users are kept aware of the non-IT-related requirements of this Policy and of all related legislation, regulations, and other relevant rules whether now or in the future in force including, but not limited to, the GDPR.

3.3           The IT Staff shall be responsible for the following:

  1. assisting all Users in understanding and complying with the IT-related aspects of this Policy;
  2. providing all Users with appropriate support and training in IT security matters and use of IT Systems;
  3. ensuring that all Users are granted levels of access to IT Systems that are appropriate for each User, taking into account their job role, responsibilities, and any special security requirements;
  4. receiving and handling all reports relating to IT security matters and taking appropriate action in response including, in the event that any reports relate to personal data, informing the Operations Director;
  5. taking proactive action, where possible, to establish and implement IT security procedures and raise User awareness;
  6. assisting the IT Manager in monitoring all IT security within the Company and taking all necessary action to implement this Policy and any changes made to this Policy in the future; and
  7. ensuring that regular backups are taken of all data stored within the IT Systems at intervals no less than daily and that such backups are stored at a suitable location onsite and offsite. All backups should be encrypted.

3.4           The Operations Director shall be responsible for the following:

  1. assisting all Users in understanding and complying with the non-IT-related aspects of this Policy;
  2. providing all Users with appropriate support and training in data security matters;
  3. ensuring that all Users are granted levels of access to data that are appropriate for each User, taking into account their job role, responsibilities, and any special security requirements;
  4. receiving and handling reports concerning non-IT-related data security matters and taking appropriate action in response;
  5. taking proactive action, where possible, to establish and implement security procedures and raise User awareness; and
  6. assisting the Managing Director in monitoring data security within the Company and taking all necessary action to implement this Policy and any changes made to this Policy in the future.

4. Users’ Responsibilities

4.1           All Users must comply with all relevant parts of this Policy at all times when using the IT Systems and data.

4.2           All Users must use the IT Systems and data only within the bounds of Irish law and must not use the IT Systems or data for any purpose or activity which is likely to contravene any Irish law whether now or in the future in force.

4.3           Users must immediately inform the IT Department and/or the Operations Director of any and all security concerns relating to the IT Systems or data.

4.4           Users must immediately inform the IT Department of any other technical problems (including, but not limited to, hardware failures and software errors) which may occur on the IT Systems.

4.5           Any and all deliberate or negligent breaches of this Policy by Users will be handled as appropriate under the Company’s disciplinary procedures.

5. Software Security Measures

5.1           All software in use on the IT Systems (including, but not limited to, operating systems, individual software applications, and firmware) will be kept up-to-date and any and all relevant software updates, patches, fixes, and other intermediate releases will be applied at the sole discretion of the IT Department. This provision does not extend to upgrading software to new ‘major releases’ (e.g. from version 1.0 to version 2.0), only to updates within a particular major release (e.g. from version 1.0 to version 1.0.1 etc.). Unless a software update is available free of charge it will be classed as a major release, falling within the remit of new software procurement and outside the scope of this provision.

5.2           Where any security flaw is identified in any software that flaw will be either fixed immediately or the software may be withdrawn from the IT Systems until such time as the security flaw can be effectively remedied. If the security flaw affects, is likely to affect, or is suspected to affect any personal data, the Operations Director shall be informed immediately.

5.3           No Users may install any software of their own, whether that software is supplied on physical media or whether it is downloaded, without the approval of the IT Manager. Any software belonging to Users must be approved by the IT Manager and may only be installed where that installation poses no security risk to the IT Systems and where the installation would not breach any licence agreements to which that software may be subject.

5.4           All software will be installed onto the IT Systems by the IT Department unless an individual User is given written permission to do so by the IT Manager. Such written permission must clearly state which software may be installed and onto which computer(s) or device(s) it may be installed.

6. Anti-Virus Security Measures

6.1           Most IT Systems (including all computers and servers) will be protected with suitable anti-virus, firewall, and other suitable internet security software. All such software will be kept up-to-date with the latest software updates and definitions.

6.2           All IT Systems protected by anti-virus software will be subject to a full system scan at least once monthly.

6.3           All physical media (e.g. USB memory sticks or disks of any kind) used by Users for transferring files must be virus-scanned before any files may be transferred. Such virus scans shall be performed automatically upon connection / insertion of media.

6.4           Users shall be permitted to transfer files using cloud storage systems only with the approval of the IT Manager. All files downloaded from any cloud storage system must be scanned for viruses during the download process.]

6.5           Any files being sent to third parties outside the Company, whether by email, on physical media, or by other means (e.g. shared cloud storage) must be scanned for viruses before being sent or as part of the sending process, as appropriate. All email attachments are scanned automatically upon sending.

6.6           Where any virus is detected by a User this must be reported immediately to the IT Department (this rule shall apply even where the anti-virus software automatically fixes the problem). The IT Department shall promptly take any and all necessary action to remedy the problem. In limited circumstances this may involve the temporary removal of the affected computer or device. Wherever possible a suitable replacement computer or device will be provided immediately to limit disruption to the User.

6.7           If any virus or other malware affects, is likely to affect, or is suspected to affect any personal data, in addition to the above, the issue must be reported immediately to the Operations Director.

6.8           Where any User deliberately introduces any malicious software or virus to the IT Systems this will constitute a criminal offence under the Criminal Damage Act 1991 and will be handled as appropriate under the Company’s disciplinary procedures.

7. Hardware Security Measures

7.1           Wherever practical, IT Systems will be located in rooms which may be securely locked when not in use or, in appropriate cases, at all times whether in use or not (with authorised Users being granted access by means of a key, smart card, door code or similar). Where access to such locations is restricted, Users must not allow any unauthorised access to such locations for any reason.

7.2           All IT Systems not intended for normal use by Users (including, but not limited to, servers, networking equipment, and network infrastructure) shall be located, wherever possible and practical, in secured, climate-controlled rooms and/or in locked cabinets which may be accessed only by designated members of the IT Department.

7.3           No Users shall have access to any IT Systems not intended for normal use by Users (including such devices mentioned above) without the express permission of the IT Manager. Under normal circumstances, whenever a problem with such IT Systems is identified by a User, that problem must be reported to the IT Department. Under no circumstances should a User attempt to rectify any such problems without the express permission (and, in most cases, instruction and/or supervision) of the IT Manager.

7.4           All non-mobile devices (including, but not limited to, desktop computers, workstations, and monitors) shall, wherever possible and practical, be physically secured in place with a suitable locking mechanism. Where the design of the hardware allows, computer cases shall be locked to prevent tampering with or theft of internal components.

7.5           All mobile devices (including, but not limited to, laptops, tablets, and smartphones) provided by the Company should always be transported securely and handled with care. In circumstances where such mobile devices are to be left unattended they should be placed inside a lockable case or other suitable container. Users should make all reasonable efforts to avoid such mobile devices from being left unattended at any location other than their private homes or Company premises. If any such mobile device is to be left in a vehicle it must be stored out of sight and, where possible, in a locked compartment.

7.6           The IT Department shall maintain a complete asset register of all IT Systems. All IT Systems shall be labelled, and the corresponding data shall be kept on the asset register.

8. Organisational Security

8.1           All Users handling data (and in particular, personal data) personal data will be appropriately trained to do so.

8.2           All Users handling data (and in particular, personal data) will be appropriately supervised.

8.3           All Users handling data (and in particular, personal data) shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to such data, whether in the workplace or otherwise.

8.4           Methods of collecting, holding, and processing data (and in particular, personal data) shall be regularly evaluated and reviewed.

8.5           All personal and non-personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy.

8.6           The performance of those Users handling personal data shall be regularly evaluated and reviewed.

8.7           All Users handling personal data will be bound to do so in accordance with the principles of the GDPR and the applicable Company Policies by contract.

8.8           No data, personal or otherwise, may be shared informally and if a User requires access to any data, personal or otherwise, that they do not already have access to, such access should be formally requested from the Operations Director.

8.9           No data, personal or otherwise, may be transferred to any unauthorised User without the authorisation of the Operations Director.

8.10        All data must be handled with care at all times and should not be left unattended or on view to unauthorised Users or other parties at any time.

9. Access Security

9.1           Access privileges for all IT Systems and data shall be determined on the basis of Users’ levels of authority within the Company and the requirements of their job roles. Users shall not be granted access to any IT Systems or data which are not reasonably required for the fulfilment of their job roles.

9.2           All IT Systems (and in particular mobile devices including, but not limited to, laptops, tablets, and smartphones) shall be protected with a secure password or passcode, or such other form of secure log-in system as the IT Department may deem appropriate and approve. Not all forms of biometric log-in are considered secure. Only those methods approved by the IT Department may be used.

9.3           All passwords must, where the software, computer, or device allows:

  1. be at least 8 characters long;
  2. contain a combination of upper and lower case letters and numbers;
  3. be changed at least every 90 days;
  4. be different from the previous password;
  5. not be obvious or easily guessed (e.g. birthdays or other memorable dates, memorable names, events, or places etc.); and
  6. be created by individual Users.

9.4           Passwords should be kept secret by each User. Under no circumstances should a User share their password with anyone, including the IT Manager and the IT Staff. No User will be legitimately asked for their password by anyone at any time and any such request should be refused. If a User has reason to believe that another individual has obtained their password, they should change their password immediately and report the suspected breach of security to the IT Department and, where personal data could be accessed by an unauthorised individual, the Operations Director.

9.5           If a User forgets their password, this should be reported to the IT Department. The IT Department will take the necessary steps to restore the User’s access to the IT Systems which may include the issuing of a temporary password which may be fully or partially known to the member of the IT Staff responsible for resolving the issue. A new password must be set up by the User immediately upon the restoration of access to the IT Systems.

9.6           Users should not write down passwords if it is possible to remember them. If a User cannot remember a password, it should be stored securely (e.g. in a locked drawer or in a secure password database) and under no circumstances should passwords be left on display for others to see (e.g. by attaching a note to a computer display).

9.7           All IT Systems with displays and user input devices (e.g. mouse, keyboard, touchscreen etc.) shall be protected, where possible, with a password protected screensaver that will activate after 10mn of inactivity. This time period cannot be changed by Users and Users may not disable the screensaver. Activation of the screensaver will not interrupt or disrupt any other activities taking place on the computer (e.g. data processing).

9.8           All mobile devices (including, but not limited to, laptops, tablets, and smartphones) provided by the Company shall be set to lock, sleep, or similar, after 2mn of inactivity, requiring a password, passcode, or other form of log-in to unlock, wake, or similar. Users may not alter this time period.

9.9           Users may not use any software which may allow outside parties to access the IT Systems without the express consent of the IT Manager. Any such software must be reasonably required by the User for the performance of their job role and must be fully inspected and cleared by the IT Manager [and, where such access renders personal data accessible by the outside party, the Data Protection Officer].

9.10        Users may connect their own devices (including, but not limited to, laptops, tablets, and smartphones) to the Company network subject to the approval of the IT Department. Any and all instructions and requirements provided by the IT Department governing the use of Users’ own devices when connected to the Company network must be followed at all times. Users’ use of their own devices shall be subject to, and governed by, all relevant Company Policies (including, but not limited to, this Policy) while those devices are connected to the Company network or to any other part of the IT Systems. The IT Department shall reserve the right to request the immediate disconnection of any such devices without notice.

10. Data Storage Security

10.1        All data stored in electronic form, and in particular personal data, should be stored securely using passwords and data encryption.

10.2        All data stored in hardcopy format or electronically on removable physical media, and in particular personal data, should be stored securely in a locked box, drawer, cabinet, or similar.

10.3        No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise [without the formal written approval of the Data Protection Officer and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary].

10.4        No data, and in particular personal data, should be transferred to any computer or device personally belonging to a User unless the User in question is a contractor or sub-contractor working on behalf of the Company and that User has agreed to comply fully with the Company’s Data Protection Policy and the GDPR.

11. Data Protection

11.1        All personal data (as defined in the GDPR) collected, held, and processed by the Company will be collected, held, and processed strictly in accordance with the principles of the GDPR, the provisions of the GDPR and the Company’s Data Protection Policy.

11.2        All Users handling data for and on behalf of the Company shall be subject to, and must comply with, the provisions of the Company’s Data Protection Policy at all times. In particular, the following shall apply:

  1. All emails containing personal data and/or other data covered by this Policy must be encrypted;
  2. All emails containing personal data and/or other data covered by this Policy must be marked “confidential”;
  3. Personal data and/or other data covered by this Policy may be transmitted over secure networks only; transmission over unsecured networks is not permitted under any circumstances;
  4. Personal data and/or other data covered by this Policy may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
  5. Personal data and/or other data covered by this Policy contained in the body of an email, whether sent or received, should be copied directly from the body of that email, and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;
  6. All personal data and/or other data covered by this Policy to be transferred physically, including that on removable electronic media, shall be transferred in a suitable container marked “confidential”.
  7. Where any personal data and/or other data covered by this Policy is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the User must lock the computer and screen before leaving it.

11.3        Any questions relating to data protection should be referred to the Operations Director.

12. Deletion and Disposal of Data

12.1        When any data, and in particular personal data, is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it must be securely deleted and/or disposed of.

12.2        For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.

13. Internet and Email Use

13.1        All Users shall be subject to, and must comply with, the provisions of the Company’s Communications, Email and Internet Policy when using the IT Systems.

13.2        Where provisions in this Policy require any additional steps to be taken to ensure security when using the internet or email over and above the requirements imposed by the Communications, Email and Internet Policy, Users must take such steps as required.

14. Reporting Security Breaches

14.1        Subject to paragraph 14.3, all concerns, questions, suspected breaches, or known breaches that relate to the IT Systems shall be referred immediately to the Operations Director or the IT Manager or a member of the IT Staff.

14.2        Subject to paragraph 14.3, all concerns, questions, suspected breaches, or known breaches that relate to other data covered by this Policy shall be referred immediately to the Operations Director.

14.3        All concerns, questions, suspected breaches, or known breaches that involve personal data shall be referred immediately to the Operations Director who shall handle the matter in accordance with the Company’s Data Protection Policy.

14.4        Upon receiving a question or notification of a breach, the individual or department responsible shall, within 5 working days, assess the issue including, but not limited to, the level of risk associated therewith, and shall take any and all such steps deemed necessary to respond to the issue.

14.5        Under no circumstances should a User attempt to resolve a security breach on their own without first consulting the relevant individual or department (or the Operations Director, as appropriate). Users may only attempt to resolve security breaches under the instruction of, and with the express permission of, the Operations Director, as appropriate.

14.6        All security breaches, howsoever remedied, shall be fully documented.

15. Policy Review

We keep this Policy under regular review and we will place any updates on this web page: https://www.vinedigital.ie/data-protection All questions, concerns, and other feedback relating to this Policy should be communicated to the Operations Director.

16. Implementation of Policy

This Policy shall be deemed effective as of 23/05/2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.