Introduction

The Data Protection Policy employed by First Network Ltd has been developed as an extension of our commitment to combine the finest quality services with the highest level of integrity in dealing with our clients, suppliers, associates and staff. This policy has been updated to be in line with GDPR standards in our on-going commitment to protecting the privacy and security of your personal information. This policy guides you through how we collect store and use information about individuals and organisations. It will be continuously assessed against new technologies, business practices and the changing needs of everyone we deal with.

First Network Limited is a “controller” of your personal information. Our address is Rowdell Road, Northolt, UB5 5QR 

Overview

First Network Ltd needs to gather and use certain information about individuals.

These can include clients, 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.

Data protection law

The Data Protection Act 1998 describes how organisation – including First Network 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 state 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

People, risks and responsibilities

Policy scope

This policy applies to:

• The office/warehouse facility of First Network Ltd
• All staff and volunteers of First Network Ltd
• All contractors, suppliers and other people working on behalf of First Network 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 First Network 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.

Responsibilities

Everyone who works for or with First Network Ltd 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 First Network Ltd meets its legal obligations.

The Data Protection Officer, Daljit Sohal, 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 First Network Ltd 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.

The IT Manager, Claire Maisey, is responsible for:

• Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
• Performing regular checks and scans to ensure security hardware and software is functioning properly.
• Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

The Marketing Manager, Suzie Douglas, is responsible for:

• Approving any data protection statements attached to communications such as emails and letters.
• Addressing any data protection queries from journalists or media outlets like newspapers.
• 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 their line managers.
• 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 their line manager or the 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.

• 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 locked drawer or filing cabinet.
• 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

The sharing of data is a contractual requirement which enables First Network to provide products and services to clients, suppliers and employees. This data is therefore necessary for the smooth running of the business. 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 First Network Ltd 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 First Network Ltd 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 Client’s details when they call.
• First Network Ltd will make it easy for data subjects to update the information First Network Ltd holds about them.
• Data should be updated as inaccuracies are discovered. For instance, if a client 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 First Network 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 email address: daljit.sohal@first-network.com. 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, First Network 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.

Providing information

First Network 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

Website and Marketing Privacy Policy

Use of Cookies

Our websites (www.firstnetworkevents.com www.first-network.com and  www.firstnetwork.com) use cookies to enhance the user’s personal experience while visiting the website.

Where applicable the website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device.

This complies with legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.

Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.

Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.

Marketing Information / Disclosure

First Network Ltd may use any information submitted to provide you with further information about the products / services they offer or to assist you in answering any questions or queries you may have submitted.

If, at any time after registering, you would like to opt-out from receiving communications from us you can do this at any time by clicking unsubscribe on any of our emails.

Although this website only looks to include quality, safe and relevant external links, users are advised adopt a policy of caution before clicking any external web links mentioned throughout this website.

The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Communication and engagement taken through external social media platforms that this website and its owners participate on are also subject to the terms and conditions of this privacy policy.

Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. Neither the website nor its owners will ever ask for personal or sensitive information through social media platforms. First Network Ltd encourages users wishing to discuss sensitive details to

Right to withdraw consent (Opt Out)

In any circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us at info@firstnetwork.com or at the above address.  Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

First Network Ltd Data Protection Policy has been developed out of respect for the privacy preferences and choices of our candidates, suppliers customers, associates and staff. We have established procedures to ensure that every reasonable effort is made to address your concerns.

If you have any concerns or questions about our use of your information you have the right to complain to the Information Commissioners Office but please inform us first, preferably by e-mail to info@firstnetwork.com so that we may have the opportunity to address any issues directly with you.