DATA PROTECTION POLICY FOR ASCENT CYBER
This policy sets out how Ascent Cyber Ltd seeks to protect personal data that we either control or process.
Ascent Cyber Ltd management team are committed to ensuring that all personal data in our possession including employees, clients, suppliers and other individuals’ data are managed and protected. We have identified those people in our organisation who are responsible data and trained them accordingly.
Ascent Cyber Ltd’s target group is business to business and do not actively work with minors. Therefore, we have identified their legal rights as;
The right of access
The right to rectify inaccuracies
The right to request data portability
The right to be forgotten
The right to object
The right to restrict processing
Ascent Cyber Ltd will identify in separate procedures how these rights will be implemented.
We will process data adhering to the following legal principles
processed lawfully, fairly and in a transparent manner in relation to the data subject (lawfulness, fairness and transparency);
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (purpose limitation);
adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (data minimisation);
accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (accuracy);
kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (storage limitation); and
processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (integrity and confidentiality).
Data Subject Access
Individuals may make a subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.
Individuals wishing to make a SAR should do so by contacting Ascent Cyber via the “Contact Us” page on https://www.ascentcyber.co.uk.
Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.
All data subject access requests will be provided in return, in a commonly used electronic format.
The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
Rectification of Personal Data
Data subjects have the right to require Ascent Cyber to rectify any of their personal data that is inaccurate or incomplete.
Ascent Cyber shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing Ascent Cyber of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.
Erasure of Personal Data
Unless Ascent Cyber has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so.)
Where data subjects have given their consent to Ascent Cyber to process their personal data in such a manner, or the processing is otherwise required for the performance of a contract between Ascent Cyber and the data subject, data subjects have the right, under the GDPR, to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers).
To facilitate the right of data portability, Ascent Cyber shall make available all applicable personal data to data subjects in a commonly used electronic format.
Where technically feasible, if requested by a data subject, personal data shall be sent directly to the required data controller.
All requests for copies of personal data shall be complied with within one month of the data subject’s request. The period can be extended by up to two months in the case of complex or numerous requests. If such additional time is required, the data subject shall be informed.
Objections to Personal Data Processing
Data subjects have the right to object to Ascent Cyber processing their personal data based on legitimate interests, direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.
Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.
Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.
Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the GDPR, “demonstrate grounds relating to his or her particular situation”. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.
If you wish to complain please contact Ascent Cyber via the “Contact Us” page on https://www.ascentcyber.co.uk.
This Policy shall be deemed effective as of 01/06/19. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
This Policy has been approved and authorised by the Board of Directors.