Data protection policy
Context and overview
Key details
● Policy prepared by: 5th May 2018
● Approved by board / management on: 20th May 2018
● Policy became operational on: 20th May 2018
● Next review date: 20th May 2020
Introduction
WasteAction Resource Efficiency Ltd and Warp It need 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 will 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 WasteAction Resource Efficiency Ltd:
● Complies with data protection law and GDPRS 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 1998 describes how organisations — including WasteAction
Resource Efficiency Ltd— 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 eight important principles. These say that
personal data must:
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
GDPR
Replaces. Data Protection Directive. Current legislation on 25th May 2018
The General Data Protection Regulation (GDPR) (EU) 2016/679 is a
regulation in EU law on data protection and privacy for all individuals within
on the European Union. It addresses the export of personal data outside the
EU.
People, risks and responsibilities
Policy scope
This policy applies to:
● The head office of WasteAction Resource Efficiency Ltd
● All staff of Waste Action Resource Efficiency Ltd
● All contractors, suppliers and other people working on behalf of Waste Action
Resource Efficiency Ltd
It applies to all data that the company holds relating to identifiable individuals. This
includes, for the company:
● Full names of Individuals
● Work postal addresses
● Work Email addresses
● Work Telephone numbers
● plus any other information relating to individuals that have come to our
attention via review or marketing calls and that is documented in the CRM
currently hubspot
Responsibilities
Everyone who works for or with WasteAction Resource Efficiency Ltd has
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 Directors is ultimately responsible for ensuring that Waste Action
Resource Efficiency meets its legal obligations.
● The Data protection Officer, Alexandra O’Connor, is responsible for:
o Keeping the board updated about data protection responsibilities,
risks and issues.
o Reviewing all data protection procedures and related policies, in line
with an agreed schedule.
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 Waste Action
Resource Efficiency Ltd holds about them (also called ‘subject access
requests’).
o Checking and approving any contracts or agreements with third
parties that may handle the company’s sensitive data.
● The software development company, Eightlegged.com, is responsible for:
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 Considering any issues that relate to the running of the system and
usability of the site.
● The server management company, Rapid Switch an Iomart company, is
responsible for:
o The security and management of the server where Warp It data is
help for WasteAction Resource Efficiency Ltd
o Take a look at their website here
● The Marketing Manager, Daniel O’Connor, is responsible for:
o Approving any data protection statements attached to
communications such as emails and letters.
o Compliancy to any bought in lists.
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 are those who
need it for their work.
● Data is not be shared informally. All data is accessed only by those employees
who need it to maintain the running of the site.
● WasteAction Resource Efficiency Ltd provides training to all employees to
help them understand their responsibilities when handling data.
● Employees will 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 will not be disclosed to unauthorised people, either within the
company or externally.
● Data will be reviewed and updated if it is found to be out of date. If no
longer required, it will be deleted and disposed of.
● Employees will request help of their data protection officer if they are unsure
about any aspect of data protection.
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.
Data is will not be stored on paper.
These guidelines also apply to data that is usually stored electronically but has been
printed out for some reason:
● The WasteAction Resource Efficiency Ltd It offices are not customer facing
and as such do not have unauthorised people entering of leaving at will,
however if in the rare circumstances that an unauthorised person does enter,
a workperson for example then all paper data should be removed from sight.
● 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 is protected by strong passwords on the individual computers, that are
changed regularly and never shared between employees.
● In the unlikely event data needs to be stored on removable media (like a CD
or DVD), these are be kept locked away securely when not being used.
● Data will only be stored on designated drives and servers, and is only
uploaded to an approved cloud computing services that is GDPRS compliant -
currently hubspot.
● Servers containing personal data should be sited in a secure location, away
from general office space. (See further detail below)
● Data is be backed up frequently. Those backups should be tested regularly, in
line with the company’s standard backup procedures. (see below)
● Data is 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.
Hosting Provider & Data Location
The hosting provider is WasteAction Resource Efficiency Ltd.
WasteAction Resource Efficiency Ltd have servers in a large DC which is securely
fenced, with CCTV cameras to monitor the premises. Inside we have a secure data
floor with multiple zones for hosting rack mounted or ATX boxes. The site has many
fail systems e.g Multiple generators, different connections into/out of the DC.
The primary data being stored and backed up in Maidenhead, KENT, UK.
Up to a 10GB connection of network bandwidth is available. Scalability is Extremely
Large provided for by additional computing power or storage.
Data Access, Security, Log in, Segregation & Encryption
Personal user data includes work address, email and telephone number. Passwords
are encrypted. Records of user trades of surplus items are also stored. This data is
stored only and is not shared with any third parties.
Data is stored in a dedicated environment. RapidSwitch, a trading name of Iomart
Hosting Ltd and Eightlegged.com have access to the infrastructure, hardware,
software and data.
The primary data encrypted using TDE & Hash User sign on via Secure login over
https.
Database and the login routines are encrypted to SHA256 standard.
Hosting Facility Security
The Data Centre has a secure fence around the premises with a gated entrance only
accessible to staff. Visitors must provide photographic ID when visiting and will be
recorded on our database. Only technicians have access to the Data Floor. Security
of the hosting facility is reviewed every 6 months for ISO accreditation.
Customer data is never transferred to laptop, netbook or other portable devices
either as part of the normal operation of the service or as part of the development
or maintenance of the service.
The relevant accreditations for the hosting environment - i.e. the physical security
and the security around systems pertaining to the environment is ISO 27001 and
9001.
Business Continuity & Disaster Recovery
Please see below for business continuity & disaster recovery options available as part of
the standard services.
WasteAction Reuse Portal (Warp It)
Backup Policy
Introduction
Warp It by WasteAction Resource Efficiency Ltd is committed to managing its customers
records including regular backups and archives.
Definitions - To back up data is to copy to another medium or storage so that, if the
active data is lost, it can be recovered in a recent if not completely current version.
Backup is primarily intended for disaster recovery, and the assumption is that in most
cases the backed-up data will not be read.
Policy
The objectives of this Policy are to:
● identify and store records of transactions on the Warp It exchange
system.
● keep the records safe and secure
● take all necessary steps to ensure the safety and security
● describe access arrangements
Back up management
The files which are backed up are
● All company portal transactions
● Uploads of items/ resources (photos etc)
● User transactions within and between organisations
● All transactions details including the financial and environmental
reporting values.
● Log in records
● Company account settings
● User account settings
Where data contains personal information- for example the user account area, there
is only one master file and one backup copy. This is for security reasons.
Central backup of data
WasteAction Resource Efficiency Ltd maintains backups of the data specified above.
Backups of each customer portal , all data and of all items, users and transaction will
be taken everyday.
Access Policy
The administrator for each portal can download transaction data at any time in the
settings dashboard. Administrators can view all transaction details from this tool.
Access to additional data on customer portals can be made by emailing
dataprotection@warp-it.co.uk with 14 days notice and specific data required.
Data use
Data use
Personal data is of no value to WasteAction Resource Efficiency Ltd 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 must ensure the screens of
their computers are always locked when left unattended.
● Personal customer data will not be shared informally. In particular, it will in
most cases, not be sent by email, unless to comply with the running of the
contract. However prospect data will be shared via email with compliant 3rd
parties.
● Data must be encrypted before being transferred electronically. The IT
manager can explain how to send data to authorised external contacts.
● Customer Personal data will never be transferred outside of the European
Economic Area.
● Employees will 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 Waste Action Resource Efficiency 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 will not create any
unnecessary additional data sets.
● Staff will take every opportunity to ensure data is updated. For instance, by
confirming a customer’s details when they call.
● Waste Action Resource Efficiency Ltd will make it easy for data subjects to
update the information Waste Action Resource Efficiency Ltd holds about
them. For instance, via the company website.
● Data will 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.
Subject access requests
All individuals who are the subject of personal data held by Waste Action Resource
Efficiency Ltd are entitled to:
● Ask what information the company holds about them and why.
● Ask how to gain access to it.
● Be informed how to keep it up to date.
● Be informed how the company is meeting its data protection obligations.
If an individual contacts the company requesting this information, this is called a
subject access request.
Subject access requests from individuals should be made by email, addressed to the
data controller at dataprotection@warp-it.co.uk. The data controller can supply a
standard request form, although individuals do not have to use this.
Individuals will be charged £10 per subject access request. The data controller will
aim to provide the relevant data within 14 days.
The data controller will always verify the identity of anyone making a subject access
request before handing over any information.
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.
Under these circumstances, Waste Action Resource Efficiency Ltd will disclose
requested data. However, the data controller will ensure the request is legitimate,
seeking assistance from the board and from the company’s legal advisers where
necessary.
To complete transactions with third parties, in this case, other approved Warp It
institutions for the express purpose of reusing surplus assets, we will share personal
data. Notably this will only include collected data of Full Name and works email
address
We also collect transactional data for reporting. This will not include any personal
data and is just the KPI gathered within the processes of the system. This data may
be used by WasteAction Resource Efficiency Ltd and other third parties for
promotion, reporting and press releases. There is no licence agreement needed for
this kind of data sharing. If you would like to know more about the data included
then please refer to https://www.warp-it.co.uk/report-guide
Providing information
WasteAction Resource Efficiency Ltd aims to ensure that individuals are aware that
their data is being processed, and that they understand:
● How the data is being used
● How to exercise their rights
To these ends, the company has a privacy policy, setting out how data relating to
individuals is used by the company.
This is available on request. And a copy of this policy is also available on the
company’s website at https://www.warp-it.co.uk/policy
Data Breach resolutions
Common Issues/ Questions
Identifying and monitoring unauthorised users and unapproved behaviour from
approved users.
Definition
Authorised users are those who have been approved by the administrator in the
customer organisation. Unauthorised users are those who have not been approved
by any admin and are accessing the system illegally and outside of the Warp It T&C’s.
Please note: In some cases there could be attacks by authorised users (disgruntled
staff for example).
Collected data
The following collected data is the limit of our data collection for our customers. We do
not collect or require any sensitive data.
● work email address
● work address
● work telephone number
● encrypted password
Passwords are stored, but they are protected by a cryptographic hash function.
Records of user trades of surplus items are also stored. This data is stored only and is not
shared in anyway.
Physical protection
The hosting location is Maidenhead, KENT, UK . The servers are stored in a large Data
Centre which is securely fenced, with CCTV cameras to monitor the premises. Inside we
have a secure data floor with multiple zones for hosting rack mounted or ATX boxes.
The Data Centre has a secure fence around the premises with a gated entrance only
accessible to staff. Visitors must provide photographic ID when visiting and will be
recorded on our database. Only technicians have access to the Data Floor. Security of
the hosting facility is reviewed every 6 months for ISO accreditation.
Customer data is never transferred to laptop, netbook or other portable devices either
as part of the normal operation of the service or as part of the development or
maintenance of the service.
The relevant accreditations for the hosting environment - i.e. the physical security and
the security around systems pertaining to the environment is ISO 27001 and 9001. These
certifications are predominantly used in the UK but are an international standard.
Unauthorised access; What do we monitor for?
Networks and computers are monitored and usage logged. Logs are kept secure and are
only available to personnel authorised by Warp It and will only be kept as long as
necessary in line with current data protection guidelines. As of May 5th 2018 we deem
it necessary to retain customer data within the Warp It portal for up to 18 months. This
means there is no loss of record data or transaction report data if either the customer
returns to their subscription within 1 year or there is an issue that needs to be resolved.
After this time the data regarding the individual will be removed and replaced by non
identifying code thus retaining the transaction data.
Warp It and our Software Partner Eightlegged.com networks and access records are
monitored and logged for all lawful purposes including: -
● Ensuring use is authorised
● Management of systems
● Protecting against unauthorised access
● Verifying security procedures
● System and operational security
● Compliance with Warp It terms and conditions
● Detection and prevention of crime
How do we know when unauthorised access happens?
● Logs for all hardware, physical security, applications and databases are
collected centrally and monitored for unusual behaviour.
● All events that fall outside of the 'normal' threshold are emailed to the
on call engineer.
● Short term auto banning systems are in place for user accounts and IP
addresses that perform unusual activity.
● There is an escalation process in place for all urgent incidents
The Data Protection Officer (from Warp It and/or Eightlegged.com) may do so
through any unusual activity and monitoring of logs. Events are monitored and alerts
raised when unusual activity occurs.
System administrators may do so by observing suspicious system behaviour. Any
member of the Warp It community may identify a potential security incident though
external complaint/notification, or other knowledge of impermissible use or
disclosure of Data.
The aim of our intruder detection system is to actively monitor for unusual or
suspicious behaviour. Warp It monitor this in several ways, by automated systems
that track and analyse behaviours patterns in logs or system usage. Remediation can
range from temporarily ban users and IP ranges based on suspicious activity, and by
hands on intervention and analysis to higher level events. Objectives of the intruder
detection system are
● Actively search for signs of unauthorised intrusion
● Prevent or detect the confidentiality of Warp It data on the network
● Preserve the integrity of Warp It data on the network
● Prevent unauthorised use of Warp It systems
● Keep hosts and network resources available to authorised users
● Increase security by detecting weaknesses in systems and network
design early
How will we notify you of a security breach?
Our internal security breach process is summarised below.
The Warp It engineer from eightlegged.com responsible for support of the system is
expected to:
● Report the attack to Alexandra O’Connor Data Protection and Daniel
O’Connor CEO at Warp It.
● Block or prevent escalation of the attack
● Investigation of the incident and preservation of evidence
● Daniel O’Connor (Warp It) to report incident to customer within 24
hours via phone (or some other method at the customers request)
● Repair the resultant damage to the system
Any suspected intrusions, suspicious activity, or unexplained erratic behaviour will be
reported to the customer within 24 hours by a communication method of their choice.
Customers administrators are also expected to report any suspicious activity as soon as
it is recognised.
Who will have access to your data?
Data is stored in a dedicated environment. RapidSwitch, a trading name of iomart
Hosting Ltd (hosting company) and Eightlegged.com (software developer) have
access to the infrastructure, hardware, software and data.
Staff within WasteAction Resource Efficiency and Eightlegged.com in line with our
privacy policy at www.warp-it.co.uk/policy
The administrator in the institution can download transaction data at any time in the
settings dashboard. Administrators can view all transaction details from this tool.
Access to additional data on customer portals can be made by emailing
dataprotection@warp-it.co.uk with 14 days notice and specific data required.