Data Protection Policy

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  1. Data protection principles 

Markoni Computing is committed to processing data in accordance with its responsibilities under the  GDPR.  

Article 5 of the GDPR requires that personal data shall 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 GDPR in order to  safeguard the rights and freedoms of individuals; and 
  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.” 
  7. We comply with the GDPR and do not knowingly collect any information of children below the age of 16 years of age without parental/guardians consent. If brought into our knowledge, we will  immediately delete it. 
  8. General provisions 
  9. This policy applies to all personal data processed by Markoni.  
  10. The Responsible Person shall take responsibility for Markoni’s ongoing compliance with this  policy.  
  11. This policy shall be reviewed at least annually.  
  12. Markoni Computing shall register with the Information Commissioner’s Office as an organisation  that processes personal data. 
  13. Lawful, fair and transparent processing  
  14. To ensure its processing of data is lawful, fair and transparent, Markoni shall maintain a Register  of Systems.  
  15. The Register of Systems shall be reviewed at least annually.  
  16. Individuals have the right to access their personal data and any such requests made to Markoni  shall be dealt with in a timely manner.  
  17. Lawful purposes 
  18. All data processed by Markoni must be done on one of the following lawful bases: consent,  contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).  
  19. Markoni Computing shall note the appropriate lawful basis in the Register of Systems. 
  20. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent  shall be kept with the personal data.  
  21. 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 Markoni’s systems.  
  22. Data minimisation 
  23. Markoni Computing shall ensure that personal data are adequate, relevant and limited to what is  necessary in relation to the purposes for which they are processed.  
  24. Accuracy 
  25. Markoni Computing shall take reasonable steps to ensure personal data is accurate.  
  26. 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.  
  27. Archiving / removal 
  28. To ensure that personal data is kept for no longer than necessary, Markoni Computing shall put in place an archiving policy for each area in which personal data is processed and review this  process annually.  
  29. The archiving policy shall consider what data should/must be retained, for how long, and why.  
  30. Security 
  31. Markoni shall ensure that personal data is stored securely using modern software that is kept-up to-date.  
  32. 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.  
  33. 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. 
  34. 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, Markoni Computing shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the  ICO website).  

END OF POLICY