Data Protection Policy

Introduction

City Office NI Ltd 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 City Office NI Ltd:

• Complies with data protection law and follows good practice.
• Protects the rights of staff, customers and partners.
• Is open about how it stores and processes individuals’ data.
• Protects itself from the risks of a data breach.

Data protection law

The General Data Protection Regulation (2018) describes how organisations like City Office NI Ltd must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The General Data Protection Regulation (2018) is underpinned by six principles. These say that personal data must be:

1. Processed lawfully, fairly and in a transparent manner in relation to individuals.
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.
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
4. 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.
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 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 General Data Protection Regulation (2018) in order to safeguard the rights and freedoms of individuals.
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 measure.

Policy scope

This policy applies to:

• The head office of City Office NI Ltd.
• All staff and volunteers of City Office NI Ltd.
• All contractors, suppliers and other people working on behalf of City Office NI Ltd.

It applies to all data that the company holds relating to identifiable individuals

• Names of individuals.
• Postal addresses.
• Email addresses.
• Telephone numbers.
• …plus any other information relating to individuals.

Data protection risks

This policy helps to protect City Office NI Ltd 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 City Office NI Ltd 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 Directors are ultimately responsible for ensuring that City Office NI Ltd meets its legal obligations.
• Due to the number of employees and the nature of the information which is processed by City Office NI Ltd, there is no dedicated Data Protection Officer but any queries can be addressed to dataprotection@cityofficeni.com or in writing to –

Data Protection

City Office NI Ltd

67 Boucher Crescent

Belfast

BT12 6HU

This includes –

1. Requests to change data (Right to Rectification)

1. Requests for deletion of data (Right to Erasure)

1. How to access your data (Subject Access Request)

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.
• City Office NI Ltd 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 Operations Director or Service Manager. 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 City Office NI Ltd unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. It should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically. The service 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 City Office NI Ltd 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 City Office NI Ltd 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.
• City Office NI Ltd will make it easy for data subjects to update the information it holds about them.
• 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.

Subject Access Requests

All individuals who are the subject of personal data held by City Office NI Ltd are entitled to:

• Ask what information the company holds about them and why.
• Ask how to gain access to it.
• Be informed how to keep it up to date.
• Be informed how the company is meeting its data protection obligations.

If an individual contacts City Office NI Ltd requesting this information, this is called a Subject Access Request. Subject access requests from individuals should be made by email, addressed to dataprotection@cityofficeni.com or in writing to –

Data Protection

City Office NI

57 Boucher Crescent

Belfast

BT12 6HU

Requesting this information is free of charge and all requests will be responded to within one month of the request being received.

Disclosing Data for Other Reasons

In certain circumstances, the General Data Protection Regulation (2018) allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Data Protection 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

City Office NI Ltd aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How the data is being used
• How to exercise their rights