EZC Study Abroad – DATA PROTECTION POLICY
EZC Study Abroad 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.
WHY THIS POLICY EXISTS:
This data protection policy ensures EZC Study Abroad:
- Complies with data protection law and follows good practice
- Protects the rights of customers, staff and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of data breaches
PEOPLE, RISK AND RESPONSIBILITIES:
The policy applies to:
- The head office of EZC Study Abroad located at 2255 Glades Road, Boca Raton, FL 33431
- All branches of EZC Study Abroad
- All staff of EZC Study Abroad
- All contractors and people working on behalf of EZC Study Abroad
It applies to all data that the company holds relating to living individual. This can include:
- Name of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Plus any other information relating directly or indirectly to individuals
DATA PROTECTION RISKS
This policy helps to protect EZC Study Abroad from some very real data security risks, including:
- Breaches 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 hackers successfully gained access to sensitive data.
Everyone who works for or with EZC Study Abroad 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.
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 direct manager
- EZC Study Abroad will provide training to all employees to help them understand their responsibilities with handling data
- Employees should keep all data secure, by taking sensible precautions
- Personal data should not be disclosed to unauthorised people, either within the company or externally
- Data should be reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
These rules describe how and where data should be safely stored.
- 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 a particular 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 for example on a printer
- Data printouts should be shredded and disposed of safely 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 (eg CD/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 service
- Servers containing personal data should be sited in a secure location
- Data should be backed up frequently. Those back-ups should be tested regularly in line with the company’s standard back up 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 use to EZC Study Abroad 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. IT provider can explain how to send data to authorised external contacts
- 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 the data
EZC Study Abroad is required 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 EZC Study Abroad 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
- EZC Study Abroad will make it easy for data subjects to update the information EZC Study Abroad holds about them.
- Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached via saved mobile phone number, it should be removed from the database
- It is the Marketing Manager’s responsibility to ensure marketing databases are checked against industry suppression files every 6 months
SUBJECT ACCESS REQUEST
All individuals who are the subject of personal data held by EZC Study Abroad 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.
To access your data simply complete the form (INSERT SUBJECT ACCCESS REQUEST FORM) and send via email to [email protected] or post to 2255 Glades Road, Boca Raton, FL 33431 Please note proof of identification will also be required to authenticate the request
Subject access requests from individuals should be made by email, addressed to the data controller at [email protected]. The data controller can supply a standard request form, although individuals do not have to use this.
Individuals cannot be charged to honour a subject access request. The data controller will aim to provide the relevant data within 30 days.
The data controller will always verify the identity of anyone making a subject access request before handing over information.
DISCLOSING DATA FOR OTHER REASONS
In certain circumstances, personal data may be disclosed to law enforcement agencies without the consent of the data subject in line with legislation.
Under these circumstances, EZC Study Abroad will disclose requested data. However the data controller will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.
EZC Study Abroad 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
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.
Your privacy is important to EZC Study Abroad This privacy statement provides information about the personal information that EZC Study Abroad collects, and the ways in which EZC Study Abroad uses that personal information.
Personal information collection
EZC Study Abroad may collect and use the following kinds of personal information:
- [information about your use of the website]
- [information that you provide using for the purpose of registering with the website]
- [information about transactions carried out over the website]
- [information that you provide for the purpose of subscribing to the website services]
- [any other information that you send to EZC Study Abroad.]
Using personal information
EZC Study Abroad may use your personal information to:
- [administer the website;]
- [personalize the website for you;]
- [enable your access to and use of the website services;]
- [publish information about you on the website;]
- [send to you products that you purchase;]
- [supply to you services that you purchase;]
- [send to you statements and invoices;]
- [collect payments from you;]
- [send you marketing communications.]
Where EZC Study Abroad discloses your personal information to its agents or sub-contractors for these purposes, the agent or sub-contractor in question will be obligated to use that personal information in accordance with the terms of this privacy statement.
In addition to the disclosures reasonably necessary for the purposes identified elsewhere above, EZC Study Abroad may disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights.
Securing your data
EZC Study Abroad will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
EZC Study Abroad will store all the personal information you provide [on its secure servers].
[Information relating to electronic transactions entered into via this website will be protected by encryption technology.]
Cross-border data transfers
[In addition, personal information that you submit for publication on the website will be published on the internet and may be available around the world.]
You agree to such cross-border transfers of personal information.
Updating this statement
You should check this page occasionally to ensure you are familiar with any changes.
This website contains links to other websites.
EZC Study Abroad is not responsible for the privacy policies or practices of any third party.
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