Island Mobility…..Your data security is one of our priorities.
• Version 18
• April 2018
• Registration number ZA326913
• Expiry date 12th March 2019
General Data Protection Regulation ( GDPR ) will be introduced from 25th May 2018.
Island Mobility Ltd needs to gather and use certain information about individuals. Most of the data we hold on clients is with regards to VAT exemptions. If a client elects to claim VAT relief on a VAT exempt product. The client will be required to fill in a VAT self certificated exemption form. Island Mobility will be required to retain this form as it may be required to be produced in a VAT audit. This policy describes how personal data must be collected, handled and stored to meet the our data protection standards, plus meeting the new regulations that come into force from 25th May.
What are the aims of this policy.
This data protection policy ensures Island Mobility Ltd:
• Complies with data protection law that is being introduced on 25th May 2018.
• We are making it easier for you to find out how we handle your information.
• Protects the rights of clients, staff and suppliers.
• We are open about how we store and protect data.
• Protect data from the risks of a data breach.
Data protection law:
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 Data Protection Act is underpinned by eight important principles.
Data to …
1. Be processed fairly and lawfully .
2. Be obtained only for specific, lawful purposes.
3. Be adequate, relevant and not excessive.
4. Be accurate and kept up to date.
5. Not be held for any longer than necessary.
6. Processed in accordance with the rights of data subjects.
7. Be protected in appropriate ways.
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.
People, risks and responsibilities:
This policy applies to:
• All Island Mobility Ltd staff.
• All contractors, suppliers and other people working on behalf of Island Mobility Ltd.
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998.
This can include:
• Names of individuals.
• Postal addresses.
• Email addresses.
• Telephone numbers.
• Any other information relating to individuals.
Data protection risks
This policy helps to protect Island Mobility 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.
Everyone who works for or with Island Mobility Ltd has some responsibility for ensuring data is collected, stored and handled appropriately. Each individual 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 board of directors is ultimately responsible for ensuring that Island Mobility Ltd meets its legal obligations.
• Rob Horton is Data Protection Officer responsible for:
o Keeping data protection up to date.
o Reviewing all data protection procedures and related policies.
o Arranging data protection training and advice for the people covered by this policy.
o Handling data protection questions from staff and anyone else covered by this policy.
o Dealing with requests from individuals to see the data Island Mobility Ltd holds about them.
o Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
o Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
o Performing regular checks and scans to ensure security hardware and software is functioning properly.
o Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
o Approving any data protection statements attached to communications such as emails and letters.
o Addressing any data protection queries from journalists or media outlets like newspapers.
o Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
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 Rob or Julie Island Mobility 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 Rob if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be direct to Rob Horton. 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 secure area
• 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.
• We back up our data daily. Last test date for backup tested off site was 6th March 2016.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones unless authorised by Rob Horton.
• All servers and computers containing data should be protected by approved security software and a firewall.
• 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.
• 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.
The law requires Island Mobility Ltd to take reasonable steps to ensure data is kept accurate and up to date. 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.
• Island Mobility Ltd will make it easy for data subjects to update the information
• 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.
• We do NOT record phone calls for training or any other reasons. We have made the decision to have a phone system that is not connected to the internet to improve security.
Subject access requests
From 25th May 2018 individuals who are the subject of personal data held by Island Mobility Ltd are entitled to:
• Ask what information the Island Mobility holds about them and why. Most data held by Island Mobility ltd is held in regards to VAT exemption requirements.
• If clients ask how to gain access to there data. Clients should email Rob Horton ( data controller ) at or write to
32 Dodnor Lane
Isle of Wight
We will aim to provide the relevant data within 14 working days once we have verified the identity of the client requesting the data information. As we only have clients on the Isle of Wight we may require the client to provide photo id at our office in Newport.
Disclosing data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Island Mobility do receive regular visits from HMRC with regards to VAT exemptions. Under these circumstances, Island Mobility Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from company’s legal advisers where necessary.