● Email addresses

● Telephone numbers

● plus any other information relating to individuals

Data protection risks

This policy helps to protect Cryptair Ltd from some very real data security risks,


● Breaches of confidentiality. For instance, information being given out


● 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.



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

● Timothy Robertson 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 Cryptair Ltd holds about them.

o Checking and approving any contracts or agreements with third

parties that may handle the company’s sensitive data.

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 Approving any data protection statements attached to

communications such as emails and letters.

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 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.

● Cryptair Ltd will provide training to all employees to help them

understand their responsibilities when handling data.

● 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


● 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 Directors.

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

Personal data is of no value to Cryptair 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 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.

● 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 Cryptair 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

Cryptair 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 customer’s details when they call.

● Cryptair Ltd will make it easy for data subjects to update the

information Cryptair Ltd holds about them.

● Data should 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 Cryptair 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 protected].



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, Cryptair Ltd will disclose requested data. However,

Cryptair will first ensure the request is legitimate, seeking assistance from the

board and from the company’s legal advisers where necessary.


Providing information

Cryptair 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


Privacy Policy:

We collect data in the following ways:

Data is given to us by our clients

We will collect your data in a number of ways:

When someone contacts us via our website, by telephone, post, email.

Anonymous data is collected using Google Analytics scripts to help us improve the website experience.

All data is collected and stored in accordance with the above.