Privacy Policy

Data Controller

Dan Bryant

Purpose of collected Personal Data

We collect personal data only where necessary as part of our contracts. Where we do directly, we ensure we have active, informed consent. We may also collect contact details, including personal details, where necessary for communication with individuals.

Our Data Protection Policy

Introduction

Tabarin 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.

Policy aim

This data protection policy ensures that Tabarin:

Complies with data protection law and follow good practice
Protects the rights of team members, customers and partners
Is open about how it stores and processes individual’s data
Protects itself from the risks of a data breach

Data Protection Law

The General Data Protection Regulation 2018 describes how organisations (including Tabarin 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 General Data Protection Regulation is underpinned by six important principles which can be found in Article 5 of the General Data Protection Regulation. These say that personal data must be:

processed lawfully, fairly and in a transparent manner in relation to individuals;
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
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;
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; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; 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.

People, risks and responsibilities

Policy Scope

The policy applies to:

The head office of Tabarin and any other office locations.
All team member of Tabarin.
All contractors, suppliers and other people working on behalf of Tabarin.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the General Data Protection Act 2018. This can include:

Name of individuals
Postal address
Email address
Telephone numbers
…plus any other information relating to individuals

Data protection risks

This policy helps to protect Tabarin from some very real data security risks, including:

Beaches 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 a malicious outsider (hacker) successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with Tabarin has some responsibility for ensuring data is collected, stored and handled appropriately. Everything mentioned within this policy applies to our sub-contractors, too.

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:

Tim Ferns is ultimately responsible for ensuring that Tabarin meets its legal obligations.
He is also responsible for:
- Keeping the Board updated on its data protection responsibilities, risk, and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging data protection training and advice for all personnel covered by this policy.
- Handling data protection questions from team member and anyone else covered by this policy.
- Dealing with requests from individuals to see the data Tabarin holds about them (also called “Subject Access Requests”)
- Checking and approving any contracts or agreements with third parties that may handle company’s sensitive data.
- 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.
- 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 team member to ensure marketing initiatives abide by data protection principles.

General team member 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, team members can request it from their team leader.
Tabarin will provide training to all employees to help them understand their responsibilities when handling data.
Team members should keep all data secure, by taking sensible precautions and following the guidelines below.
Team members should ensure that they obtain freely given, specific, informed, and unambiguous consent to process someone’s data.
All software Tabarin provided or recommended is correctly licensed. This is applicable to software that has access to company or customer data.
All personnel, employees, and contractors are allowed to use MS Edge Wallet and Apple Wallet as their password manager and store all logins, IDs passwords using these tool. Passwords should never be shared between users to maintain an audit trail. Our staff handbook provides guidance on passwords.
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 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 Security Manager.

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 printed paper 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 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 team members.
If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being in use.
Data should only be stored on designated drives and servers and should only be uploaded to approved cloud computing services.
Servers containing personal data should be sited in a secure location, away from general office space. As Tabarin uses servers hosted by Tabarin srl and those servers are located in secure data centres.
All sensitive data such as customer data and personal identifiable information must be encrypted-at-rest using AES-256 or similar.
All sensitive data must be encrypted-in-transit during handling using SSL/TLS, SFTP, SSH or similar.
Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard for backup procedures.
Data should never be saved directly to laptops or other mobile devices like tablets or smartphones. Don’t store anything on your desktop!
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 Tabarin 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.
Personal data should never be transferred outside of the European Economic Area; however, data may be processed by a service providers based in, countries outside of the EEA. Such countries do not always provide the same level of data protection as the UK; however, where such transfers of data occur, contracts are put in place that include security obligations on Tabarin’s service providers to ensure that personal data is protected in accordance with UK standards.
Team members 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 Tabarin 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 necessary. Team member should not create any unnecessary additional data sets.
Team member should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
Tabarin will make it easy for data subjects to update the information Tabarin holds about them. Our website is under development but it will include a privacy policy and details of how people can make a subject access request or ask us to delete their personal data.
Data must 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.

Subject access requests

All individuals who are the subject of personal data held by Tabarin are entitled to:

Ask what information the company holds about them and why.
Ask how to gain access.
Be informed how to keep it up to date.
Ask how their data is being processed and for what legal purpose.
Be informed how the company is meeting its data protection obligations.
Request for their data to be removed or transferred.

If an individual contacts the company requesting this information, this is a called a subject access request.

Subject access requests from individuals should be made via email addressed to the data controller at Tabarin. The data controller can supply a standard request from, although individuals do not have to use this. The data controller will aim to provide the relevant data within one month to meet the requirements of the Data Protection Act 2018. Our procedure for data subjects rights is at the Appendix.

The data controller will always verify the identity of anyone making a subject access request before releasing any data.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act 2018 permits or requires personal data to be disclosed to law enforcement agencies or other government bodies without the prior consent of the data subject. Tabarin is also required to disclose personal data in order to enforce Tabarin’s EULA, or to protect the property, rights or safety of Tabarin, users of Tabarin’s services or others. In such case, information may be exchanged with third party companies or organisations in order to prevent fraud or reduce credit risk.

Under these circumstances, Tabarin will disclose the 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.

Disclosing data to third parties

Disclosure of personal data (including, without limitation, Client Data) to third parties will only occur if:

Tabarin sells or purchases any business or assets.
In such case, Tabarin may authorise the disclosure of personal data to prospective sellers or buyers or such business or assets.
All or the substantial majority of Tabarin’s assets are sold to a third party. In such case, personal data may be one of the transferred assets.

Further Information

Further information and advice on this policy can be obtained from the Data Controller. Comments and suggestions to improve security are always welcome.