Privacy policy

Website browsing

When someone visits our website we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the website. We collect this information in a way which does not identify anyone.

We do not make any attempt to find out the identities of those visiting our website.

We use Google Analytics to help analyse use of our website. This analytical tool uses 'cookies', which are text files placed on your computer, to collect standard internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the website (including your IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the website and to compile statistical reports on website activity for Univers AP.

Univers AP does not (and will not allow any third party) to use the statistical analytics tool to track or to collect any personally identifiable information of visitors to our site. We will not associate any data gathered from this site with any personally identifying information from any source as part of our use of the Google statistical analytics tool. Google will not associate your IP address with any other data held by Google.

If you complete a contact form, your details are not recorded on any database. They are forwarded to the a contact most suited to handling your request.

Univers AP is committed to transparency with regard to the the use of personal data.

If we do want to collect personally identifiable information through our website, we will be upfront about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Introduction

Univers AP 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 Univers AP :

• Complies with data protection law and follow 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 Data Protection Act describes how organisations — including Univers AP — 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 Data Protection Act is underpinned by seven important principles. These say that personal data must :

• Be processed fairly and lawfully
• Be obtained only for specific, lawful purposes
• Be adequate, relevant and not excessive
• Be accurate and kept up to date
• Not be held for any longer than necessary
• Processed in accordance with the rights of data subjects
• Be protected in appropriate ways

People, risks and responsibilities

Policy scope

This policy applies to :

• The Univers AP head office
• All Univers AP staff
• All contractors, suppliers and other people working on behalf of Univers AP

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection. This can include :

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

Data protection risks

This policy helps to protect Univers AP 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 Univers AP 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 board of directors is ultimately responsible for ensuring that Univers AP meets its legal obligations.

* The Managing Director, is responsible for :

• • Keeping the board updated about data protection responsibilities, risks and issues.
• • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
• • Arranging data protection training and advice for the people covered by this policy.
• • Handling data protection questions from staff and anyone else covered by this policy.
• • Dealing with requests from individuals to see the data Univers AP holds about them (also called ‘subject access requests’).
• • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

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 :

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 Univers AP 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. In particular, it should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically. The IT 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 Univers AP to 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 Univers AP 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.
• Univers AP will make it easy for data subjects to update the information Univers AP holds about them. For instance, via the company website.
• 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.

It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.