● 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.
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
● 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.
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
● Employees should not save copies of personal data to their own computers.
Always access and update the central copy of any data.
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
● 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@example.com.
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.
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
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.