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Data Security Manual for Tyler Hampshire

Version 1.2
Effective Date: 21/09 2024

1. Introduction

This Data Security Manual outlines the policies, procedures, and practices that Tyler Hampshire must follow to ensure compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. As a marketing company focused on lead generation, Tyler Hampshire handles personal data regularly, making it essential to implement robust data security measures to protect individuals’ privacy and maintain trust.

2. Scope

This manual applies to all employees, contractors, and third-party vendors who process personal data on behalf of Tyler Hampshire. It covers the collection, storage, processing, and disposal of personal data, with a specific focus on lead generation activities.

3. Key Definitions

  • Personal Data: Any information relating to an identifiable individual (e.g., name, email, phone number, IP address).
  • Data Subject: The individual whose personal data is being processed.
  • Data Controller: Tyler Hampshire, as the entity determining the purposes and means of processing personal data.
  • Data Processor: Any third party that processes personal data on behalf of Tyler Hampshire.
  • Lead Generation: The process of identifying and collecting potential customer information for marketing purposes.

4. UK GDPR Principles

Tyler Hampshire must adhere to the following UK GDPR principles:

  1. Lawfulness, Fairness, and Transparency: Process personal data lawfully, fairly, and transparently.
  2. Purpose Limitation: Collect data only for specified, explicit, and legitimate purposes.
  3. Data Minimization: Collect only the data necessary for the intended purpose.
  4. Accuracy: Ensure data is accurate and up to date.
  5. Storage Limitation: Retain data only for as long as necessary.
  6. Integrity and Confidentiality: Protect data against unauthorized access, loss, or damage.
  7. Accountability: Demonstrate compliance with UK GDPR principles.

5. Data Security Measures

5.1. Data Collection

  • Consent: Obtain explicit consent from data subjects before collecting their personal data. Use clear and concise consent forms.
  • Legitimate Interest: Where consent is not required, ensure processing is based on legitimate interests and does not override the rights of the data subject.
  • Transparency: Provide a clear privacy notice explaining how data will be used, stored, and shared.

5.2. Data Storage

  • Encryption: Encrypt all personal data stored electronically.
  • Access Control: Restrict access to personal data to authorized personnel only. Use multi-factor authentication (MFA) for systems containing personal data.
  • Data Backups: Regularly back up data and store backups securely.

5.3. Data Processing

  • Third-Party Processors: Ensure all third-party processors comply with UK GDPR. Sign Data Processing Agreements (DPAs) with vendors.
  • Data Minimization: Only process data necessary for lead generation purposes.
  • Anonymization: Where possible, anonymize data to reduce privacy risks.

5.4. Data Retention

  • Retention Policy: Retain personal data only for as long as necessary to fulfill the purpose for which it was collected.
  • Data Disposal: Securely delete or anonymize data once the retention period expires.

5.5. Data Breach Response

  • Incident Reporting: Report any data breaches to the Information Commissioner’s Office (ICO) within 72 hours of discovery.
  • Notification: Notify affected data subjects if the breach poses a high risk to their rights and freedoms.
  • Investigation: Conduct a thorough investigation to identify the cause of the breach and implement corrective measures.

6. Employee Training and Awareness

  • Training Programs: Provide regular training to employees on UK GDPR compliance and data security best practices.
  • Awareness Campaigns: Promote a culture of data security through internal communications and reminders.

7. Data Subject Rights

Tyler Hampshire must facilitate the following rights for data subjects:

  1. Right to Access: Provide data subjects with a copy of their personal data upon request.
  2. Right to Rectification: Correct inaccurate or incomplete data.
  3. Right to Erasure: Delete personal data when requested, subject to legal obligations.
  4. Right to Restrict Processing: Restrict processing under certain conditions.
  5. Right to Data Portability: Provide data in a structured, commonly used format.
  6. Right to Object: Allow data subjects to object to processing for direct marketing purposes.

8. Monitoring and Auditing

  • Regular Audits: Conduct regular audits to ensure compliance with UK GDPR and this manual.
  • Risk Assessments: Perform Data Protection Impact Assessments (DPIAs) for high-risk processing activities.
  • Record-Keeping: Maintain records of data processing activities as required by UK GDPR.

9. Third-Party Management

  • Due Diligence: Assess third-party vendors for compliance with UK GDPR before engaging their services.
  • Contracts: Include GDPR-compliant clauses in contracts with third-party processors.
  • Monitoring: Regularly monitor third-party compliance with data security requirements.

10. Incident Response Plan

  1. Identification: Detect and identify data breaches promptly.
  2. Containment: Take immediate steps to contain the breach.
  3. Assessment: Evaluate the scope and impact of the breach.
  4. Notification: Notify the ICO and affected data subjects if required.
  5. Review: Conduct a post-incident review to prevent future breaches.

11. Review and Updates

This manual will be reviewed annually or as needed to ensure ongoing compliance with UK GDPR and changes in business operations.

12. Contact Information

For questions or concerns regarding this manual or data protection practices, contact:
Data Protection Officer (DPO)
DPO@tylerhampshire.uk

By Post

Tyler Hampshire

24 Greek stStockport
SK3 8 AB