1. Data protection principles
MFH Engineering Holdings Ltd is committed to processing data in accordance with its responsibilities under the GDPR. Article 5 of the GDPR requires that personal data is:
- a. Processed lawfully, fairly and in a transparent manner in relation to individuals;
- b. 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 will not be considered to be incompatible with the initial purposes;
- c. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- d. Accurate and, where necessary, kept up to date; every reasonable step will be taken to ensure that any personal data that is inaccurate, is erased or rectified without delay
- e. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for 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
- f. 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."
2. General provisions
- a. This policy applies to all personal data processed by MFH Engineering Holdings Ltd.
- b. The Responsible Person will take responsibility for MFH Engineering Holdings Ltd.'s on-going compliance with this policy.
- c. This policy will be reviewed at least annually.
- d. MFH Engineering Holdings Ltd is registered with the Information Commissioner's Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
- a. To ensure its processing of data is lawful, fair and transparent, MFH Engineering Holdings Ltd will maintain a Register of Systems.
- b. The Register of Systems will be reviewed at least annually.
- c. Individuals have the right to access their personal data and any such requests made to MFH Engineering Holdings Ltd will be dealt with in a timely manner.
4. Lawful purposes
- a. All data processed by MFH Engineering Holdings Ltd will be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
- b. MFH Engineering Holdings Ltd will note the appropriate lawful basis in the Register of Systems.
- c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent will be kept with the personal data.
- d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available and systems will be in place to ensure such revocation is reflected accurately in MFH Engineering Holdings Ltd.'s systems.
5. Data minimisation
- a. MFH Engineering Holdings Ltd will ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- a. MFH Engineering Holdings Ltd will take all reasonable steps to ensure personal data is accurate.
- b. Where necessary for the lawful basis on which data is processed, steps will be put in place to ensure that personal data is kept up to date.
7. Archiving / removal
- a. To ensure that personal data is kept for no longer than necessary, MFH Engineering Holdings Ltd will put in place an archiving policy for each area in which personal data is processed and review this process annually.
- b. The archiving policy will consider what data will/must be retained, for how long, and why.
- a. MFH Engineering Holdings Ltd personal data is stored securely either electronically using modern software that is kept-up-to-date or hard copy files kept under lock and key with access permission severely restricted.
- b. Access to personal data is limited to personnel who need access and appropriate security is in place to avoid unauthorised sharing of information.
- c. When personal data is deleted this will be done safely such that the data is irrecoverable.
- d. Appropriate back-up and disaster recovery solutions are in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, MFH Engineering Holdings Ltd will promptly assess the risk to people's rights and freedoms and if appropriate report this breach to the Information Commissioner's Office