Introduction
Your Editing Team (“Your Editing Team”) collects and uses information about individuals (‘personal data’) in the course of business. Data protection legislation gives individuals the right to know what information is held about them and it provides a framework to ensure that personal information is handled properly. This policy sets out our expectations regarding the control of personal data handled by Your Editing Team. This includes employee, contractor, applicant, customer, prospective customer, and claimant data.
It is important that data is processed in a fair and lawful manner to:
- Protect individuals’ fundamental rights and freedoms, notably privacy rights; and
- Enable organizations to process personal information in the course of their legitimate business.
Scope
This policy covers Your Editing Team. Any Data that is processed there is covered by the relevant data protection legislation from the home jurisdiction of the Data Controller.
All employees of Your Editing Team, its agents, and contractors who work on behalf of Your Editing Team must adhere to this policy.
Definitions
For the purpose of clarity, the definitions of some common data protection terms referred to in this policy are set out below:
To access the Software, you will have a username and password. This will be set up by us and sent to you within five working days from the date of your acceptance of this License.
Personal Data
Any information that an organization holds and/or uses on living individuals, including name, address, date of birth, telephone numbers, etc.
Sensitive Data
Personal data consists of information such as medical information, criminal records, racial or ethnic origin, or political beliefs of the individual.
Processing
Any use to which personal data is put, including obtaining, retrieving, holding, storing or disposal. Examples of processing include:
- Administering or setting up client accounts
- Using data for marketing purposes
- Administering and maintaining employee records.
Cookie
A small file of letters or numbers is downloaded onto a device when the user accesses certain websites. Cookies allow a website to recognize a user’s device. In this policy, ‘cookie’ refers to all technologies that perform a similar function.
Strictly necessary cookie
A cookie whose function is explicitly requested by and therefore specifically related to the service requested by the user.
Data Controller
A person who determines the purposes for which, and the manner in which, any Personal Data are, or are to be Processed.
Data Processor
Any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
Approach
Your Editing Team has established policies (including this policy) and procedures, and allocated responsibilities, to manage the risk that information about individuals is inappropriately collected, used, disclosed, retained, or disposed of and that our statutory and regulatory obligations are complied with, including those under
- The Data Protection Act 1998, and
- The Privacy and Electronic Communication Regulations (2011).
These processes and procedures include:
Ensuring that we have the appropriate permissions to market to customers via electronic and non-electronic means, including Consent to the Use of Cookies where these are not ‘strictly necessary’, and that a suppression process is in place to prevent marketing to customers where we do not have the required permission, or where permission has been withdrawn.
Data retention standards and the use of data retention schedules to record retention periods, to ensure that we do not retain personal data longer than is necessary, that data retention is in line with statutory and regulatory requirements, and that data is destroyed appropriately when no longer required.
Data security standards to protect data from unauthorized access, alteration, or destruction. Controls include physical controls, such as building access controls and confidential waste bins; IT controls such as data encryption, backup, and system access controls. Employees are subject to vetting to assess fitness and proneness, and staff is not permitted to store customer data on laptops or take customer data out of company premises (physically or electronically) without the appropriate controls in place (including prior permission).
Data sharing protocols, to ensure that data is shared (within or outside of Your Editing Team) only where appropriate controls have been established, and the data to be shared is limited to that which is necessary, and is shared via secure methods. This includes written data sharing agreements where routine sharing of data takes place to define the responsibilities and liabilities in respect of the data disclosed or received.
In the event that there is an unfortunate data loss incident, an investigation into this shall be coordinated by the Chief Executive, the result of which will be that controls be put in place to mitigate the risk of any similar data loss. Any serious data protection breaches should be logged and procedural changes made when non-compliant trends occur.
Defined processes for dealing with subject access and other third-party requests for their personal information.
Staff training to ensure all staff are aware of their responsibilities in relation to the use of information concerning individuals, together with monitoring processes to ensure that these are being adhered to in practice.
Governance
Roles and responsibilities
Each of Your Editing Team’s Directors bears the ultimate responsibility for the management of data protection within the business. Specifically, the Directors should ensure sound governance arrangements are in place to manage, monitor, and control data protection issues.
All directors are responsible for ensuring compliance with this Policy within their area of accountability.
All employees have a responsibility to treat all personal data in an appropriate manner, in accordance with this Policy and associated guidelines and processes. Employees are required to complete training and awareness on policies, procedures, and internal controls and ensure they understand their responsibilities in relation to the use of personal data.
The Chief Executive is the appointed Data Protection Officer and is responsible for ensuring appropriate controls are in place to minimize the risk of a breach.
YOUR EDITING TEAM must ensure that when entering into a new business arrangement that the appropriate data protection clauses are included within contract documentation wherever relevant, including consideration of both the purposes for which Your Editing Team may wish to use data and the controls over the use of data by our third-party partners.
Review ownership and regularity
This policy will be reviewed at least annually. Any proposed variations or amendments to this Policy must be approved by the Chief Executive.
Non-adherence with this Policy
Non-adherence with this Policy will be dealt with through the normal company disciplinary procedures.
Reporting an Incident
To report any suspected serious misconduct or any breach or suspected breach of law or regulation, please mail to support@youreditingteam.com.
Escalation
We regard a complaint, incident, or failure as an expression of concern or dissatisfaction about our organization, our staff, our partners, our contracted service providers, or anyone else acting on our behalf. To learn more about how our problem resolution processes, please reach us at support@youreditingteam.com.
