Privacy Policy

Privacy Policy

1. About this policy

• This Privacy Standard sets out how TTOGS Limited (“we”, “our”, “us”, “the Company”) handle the Personal Data of our customers, suppliers, employees, workers and other third parties.
• During the course of our activities we will collect, store and process Personal Data and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.
• This policy does not form part of any employee’s contract of employment and may be amended at any time.
• This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer and store personal data.
• Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to Monica Chauhan.

 

1. Definitions:

• Company name: TTOGS Limited
• Company Personnel: all employees, directors, members and others.
• Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear positive action, signifies agreement to the Processing of Personal Data relating to them.
• Customer Privacy Policy: the Company’s policy in providing its customers, suppliers and other third parties detailed and specific information required by the GDPR to identify the legal grounds being relied on by the Company for each Processing activity.
• Data Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Data Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.
• Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.
• EEA: the 28 countries in the EU, and Iceland, Liechtenstein and Norway.
• Employee Privacy Policy: the Company’s policy in providing its employees and workers with detailed and specific information required by the GDPR to identify the legal grounds being relied on by the Company for each Processing activity.
• Explicit Consent: consent which requires a very clear and specific statement (that is, not just action).
• General Data Protection Regulation (GDPR): the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the GDPR.
• Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour. Personal Data includes Sensitive Personal Data.
• Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.
• Privacy Notices or Privacy Policies: separate notices setting out information that may be provided to Data Subjects when the Company collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, employee privacy notices or the website privacy policy) or they may be stand-alone, one time privacy statements covering Processing related to a specific purpose.
• Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.
• Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.
• Sensitive Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal Data relating to criminal offences and convictions.

1. Scope

• We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times. The Company is exposed to potential fines of up to EUR20 million (approximately £18 million) or 4% of total worldwide annual turnover, whichever is higher and depending on the breach, for failure to comply with the provisions of the GDPR.
• You must read this privacy standard very carefully and abide by its terms. Failure to adhere to this policy may result in disciplinary action.
• Please contact Monica Chauhan with any questions about the operation of this policy or the GDPR or if you have any concerns that this policy is not being or has not been followed.

 

1. Personal data protection principle

• We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:
• Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
• Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
• Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).
• Accurate and where necessary kept up to date (Accuracy).
• Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).
• Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).
• Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
• Made available to Data Subjects and Data Subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject’s Rights and Requests).
• We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).

 

1. Lawfulness, Fairness, Transparency

• Personal data must be processed lawfully, fairly and in a transparent manner in relation to the Data Subject.
• You may only collect, process and share Personal Data fairly and lawfully and for specified purposes. The GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing, but ensure that we process Personal Data fairly and without adversely affecting the Data Subject.
• The GDPR allows Processing for specific purposes, some of which are set out below:
• the Data Subject has given his or her Consent (see section 6);
• as identified in our Customer Privacy Policy (processing is necessary for the performance of a contract, to meet our legal compliance obligations, to protect the Data Subject’s vital interests, to pursue our legitimate interest).
• The Customer Privacy Policy will allow you to identify and document the legal ground being relied on for each Processing activity.

 

1. Consent/Transparency

• A Data Controller must only process Personal Data on the basis of one or more of the lawful bases set out in the GDPR, which include Consent.
• The GDPR requires Data Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. Such information is provided to the Data Subject via our Customer Privacy Policy or our Employee Privacy Policy.
• If you obtain Personal Data directly from a Data Subject in person, at the point that you obtain the Personal Data, you must draw their attention to our Customer Privacy Policy contained on our website.
• If you obtain Personal Data directly from the Data Subject on the telephone, you must draw the Data Subject’s attention to our Customer Privacy Policy located on our website.
• If you do not obtain Personal Data directly from the Data Subject directly, such as from a third party such UK Fast and Envisage Digital then you must send our Customer Privacy Policy to the data subject via email or post without delay and no later than one week of obtaining the Personal Data.
• If we are later instructed to act for a customer, supplier or other third party, you must request that our appropriate Terms & Conditions and Privacy Policy Acknowledgement is signed without delay.
• Data Subjects are able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured. If a Data Subject confirms that they wish to withdraw their consent, immediately notify Monica Chauhan.
• We do not envisage that you will be required to process Sensitive Personal Data. However, in the unlikely event that you obtain and are required to process Sensitive Personal Data, immediately notify Monica Chauhan because Explicit Consent will need to be obtained from the Data Subject to process such Sensitive Personal Data.
• Whenever you collect Personal Data directly from employees or workers, including for human resources or employment purposes, you must provide the Data Subject with our Employee Privacy Policy.

 

1. Purpose Limitation

• Personal Data must be collected only for specified, explicit and legitimate purposes. It must not be further processed in any manner incompatible with those purposes.
• You cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes and they have Consented where necessary.

 

1. Data Minimisation

• Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.
• You may only Process Personal Data when performing your job duties requires it. You cannot Process Personal Data for any reason unrelated to your job duties.
• You may only collect Personal Data that you require for your job duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes.
• You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company’s data retention policy.

 

1. Accuracy

• Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.
• You must ensure that the Personal Data that we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards.
• If you believe that Personal Data that we use is not accurate, complete, kept up to date or relevant for the purpose for which we collected it, you must notify Monica Chauhan without delay who may take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

 

1. Storage limitation

• Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.
• The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires such data to be kept for a minimum time. You must comply with our data retention policy.
• You must not store Personal Data or Sensitive Personal Data on any personal devices, USBs or other equipment. All Personal Data or Sensitive Personal Data must be stored and processed on our Excel database and Microsoft Office.

 

1. Security integrity and confidentiality

• Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.
• We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable).
• You are responsible for protecting the Personal Data we hold. You must implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data. You must update/change passwords every three months. You must exercise particular care in protecting Sensitive Personal Data from loss and unauthorised access, use or disclosure.
• You must follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.
• You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:
• Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it.
• Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed.
• Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.
• You must comply with and not attempt to circumvent the administrative, physical and technical safeguards we implement and maintain in accordance with the GDPR and relevant standards to protect Personal Data.

 

1. Reporting a Personal Data Breach

• The GDPR requires Data Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data Subject.
• We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.
• If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact Monica Chauhan who is designated as the key point of contact for Personal Data Breaches. You should preserve all evidence relating to the potential Personal Data Breach.

 

1. Transfer limitation

• The GDPR restricts data transfers to countries outside the EEA in order to ensure that the level of data protection afforded to individuals by the GDPR is not undermined. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country.
• If you must not transfer Personal Data outside the EEA without Monica Chauhan’s written consent.

 

1. Data Subject’s rights and requests

• Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:
• withdraw Consent to Processing at any time;
• receive certain information about the Data Controller’s Processing activities;
• request access to their Personal Data that we hold;
• prevent our use of their Personal Data for direct marketing purposes;
• ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;
• restrict Processing in specific circumstances;
• challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;
• request a copy of an agreement under which Personal Data is transferred outside of the EEA;
• object to decisions based solely on Automated Processing, including profiling (ADM);
• prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;
• be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;
• make a complaint to the supervisory authority; and
• in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine readable format.
• You must verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade you into disclosing Personal Data without proper authorisation).
• You must immediately forward any Data Subject request you receive to Monica Chauhan who will thereafter deal with the subject access request.

1. Accountability

• As a Data Controller, we have implemented appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. As Data Controller, we are responsible for, and must be able to demonstrate, compliance with the data protection principles.

 

1. Record keeping

• The GDPR requires us to keep full and accurate records of all our data Processing activities.
• You must keep and maintain accurate records reflecting our Processing including records of Data Subjects’ Consents and procedures for obtaining Consents in accordance with the Company’s guidelines.

 

1. Training and audit

• We will ensure that all Company Personnel have undergone adequate training to enable them to comply with data privacy laws.
• You must undergo all mandatory data privacy related training as requested.
• You must regularly review all the systems and processes under your control to ensure they comply with this Privacy Standard and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.

 

1. Direct marketing

• We are subject to certain rules and privacy laws when marketing to our customers.
• For example, a Data Subject’s prior consent is required for electronic direct marketing (for example, by email, text or automated calls). As per clause 6.2, at the point that you obtain Personal Data from a Data Subject, you must draw the Data Subject’s attention to our Customer Privacy Policy.
• If a Data Subject opts out at any time, contact Monica Chauhan immediately as their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.

 

1. Sharing Personal Data

• Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.
• You may only share the Personal Data we hold with another employee, agent or representative of TTOGS Limited  if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions.
• You may only share the Personal Data we hold with third parties, such as our service providers if:
• they have a need to know the information for the purposes of providing the contracted services;
• sharing the Personal Data complies with the Customer Privacy Notice provided to the Data Subject and, if required, the Data Subject’s Consent has been obtained;
• the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
• the transfer complies with any applicable cross border transfer restrictions; and
• a fully executed written contract that contains GDPR approved third party clauses has been obtained.