Policies

make:good is committed to the highest standards of ethical conduct and integrity in all its business activities. This policy outlines make:good’s position on ensuring information and data security. make:good, as an engagement supplier, often comes into contact or collects sensitive personal data, including addresses, postcodes, contact details, names and photos, and takes the custody and protection of this data most seriously. We are implementing effective measures to prevent, monitor and eliminate information and data leaks in our professional networks.    

Scope of this policy

This policy applies to all employees and officers of make:good, and to temporary workers, consultants, contractors, agents and subsidiaries acting for, or on behalf of, make:good ("associated persons”). Every employee and associated person acting for, or on behalf of, make:good is responsible for maintaining the highest standards of business conduct. Any breach of this policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned and may cause serious damage to the reputation and standing of make:good.

Policy

“Personal data” is defined as any information relating to an identified or identifiable natural person (a data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

make:good is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals. 

GDPR

This policy aims to ensure compliance with the General Data Protection Regulation. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:

 

  • processed lawfully, fairly, and in a transparent manner in relation to the data subject;

  • 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 it is processed;

  • accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is 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 is 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 Regulation in order to safeguard the rights and freedoms of the data subject;

  • 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.

 

The Regulation seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject.


The Regulation states that processing of personal data shall be lawful if at least one of the following applies:

 

  • the data subject has given consent to the processing of his or her personal data for one or more specific purposes;

  • processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;

  • processing is necessary for compliance with a legal obligation to which the controller is subject;

  • processing is necessary to protect the vital interests of the data subject or of another natural person;

  • processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

  • processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

make:good collects and processes personal data sets - this may include personal data received directly from data subjects (for example, contact details used when a data subject communicates with us) and data received from third parties.

 

make:good only processes personal data for the specific purposes (or for other purposes expressly permitted by the Regulation). The purposes for which we process personal data will be informed to data subjects at the time that their personal data is collected.

 

make:good will only collect and process personal data for and to the extent necessary for the specific purpose(s) informed to data subjects as above.

 

make:good shall ensure that all personal data collected and processed is kept accurate and up-to-date. The accuracy of data shall be checked when it is collected and at regular intervals thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

 

make:good shall not keep personal data for any longer than is necessary in light of the purposes for which that data was originally collected and processed. When the data is no longer required, all reasonable steps will be taken to erase it without delay.

 

make:good shall ensure that all personal data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage.

 

The Regulation sets out the following rights applicable to data subjects:

 

  • The right to be informed;

  • The right of access;

  • The right to rectification;

  • The right to erasure (also known as the ‘right to be forgotten’);

  • The right to restrict processing;

  • The right to data portability;

  • The right to object;

  • Rights with respect to automated decision-making and profiling.

 

Data subjects may request that make:good ceases processing the personal data it holds about them. If a data subject makes such a request, make:good shall retain only the amount of personal data pertaining to that data subject that is necessary to ensure that no further processing of their personal data takes place.

 

 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

 

make:good processes personal data using automated means via PCs and websites. Where data subjects have given their consent to process their personal data in such a manner or the processing is otherwise required for the performance of a contract between make:good and the data subject, data subjects have the legal right under the Regulation to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers, e.g. other organisations).

 

Data subjects have the right to object to make:good processing their personal data based on legitimate interests (including profiling), direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.

 

Where a data subject objects to make:good processing their personal data based on its legitimate interests, make:good shall cease such processing forthwith, unless it can be demonstrated that make:good’s legitimate grounds for such processing override the data subject’s interests, rights and freedoms; or the processing is necessary for the conduct of legal claims.

 

make good will ensure that all its employees, agents, contractors, or other parties working on its behalf comply with the following when working with personal data:

 

  • All emails containing personal data must be secure and confidential;

  • Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hardcopies should be shredded, and electronic copies should be deleted securely using secure methods.

  • Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;

  • Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;

  • Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;

  • Where Personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;

  • Where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using direct person to person methods;

  • No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of make:good requires access to any personal data that they do not already have access to, such access should be formally requested from Catherine.

  • All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet or similar;

  • No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of make:good or not, without the authorisation of Catherine;

  • Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;

  • If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it;

  • No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets and smartphones), whether such device belongs to make:good or not, of so, is  strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary.

  • No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of make:good where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Regulation ;

  • All personal data stored electronically should be backed up monthly with backups stored onsite AND by secure cloud. All backups should be secure;

  • All electronic copies of personal data should be stored securely using passwords and security;

  • All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols;

 

make:good shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

 

  • All employees, agents, contractors, or other parties working on behalf of make:good shall be made fully aware of both their individual responsibilities and make:good’s responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;

  • Only employees, agents, sub-contractors, or other parties working on behalf of make:good that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by make:good;

  • All employees, agents, contractors, or other parties working on behalf of make:good handling personal data will be appropriately trained to do so;

  • All employees, agents, contractors, or other parties working on behalf of make:good handling personal data will be appropriately supervised;

  • Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;

  • The performance of those employees, agents, contractors, or other parties working on behalf of make:good handling personal data shall be regularly evaluated and reviewed;

  • All employees, agents, contractors, or other parties working on behalf of make:good handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;

  • All agents, contractors, or other parties working on behalf of make:good handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of make:good arising out of this Policy and the Regulation;

  • Where any agent, contractor or other party working on behalf of make:good handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless make:good against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

 

All personal data breaches must be reported immediately to Catherine. If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the data protection officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.

 

In the event that a personal data breach is likely to result in a high risk to the rights and freedoms of data subjects, make:good must ensure that all affected data subjects are informed of the breach directly and without undue delay.

 

Data breach notifications shall include the following information:

a) The categories and approximate number of data subjects concerned;

b) The categories and approximate number of personal data records concerned;

c) The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);

d) The likely consequences of the breach;

e) Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

make:good responsibilities

make:good will comply with all statutory requirements of Data Protection law including the requirements of the General Data Protection Regulations (GDPR). Any personal or sensitive information on an individual which we hold is covered by this legislation. This includes emails. 

The Directors have overall responsibility for making sure that this policy complies with all our legal and ethical obligations, and that all of those under our control comply with it. Catherine has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and assessing internal control systems and procedures to make sure that they are effective in ensuring information and data security.

Employee responsibilities 

All employees are responsible for making sure that all data we deal with in all matters is protected and kept secure. You should understand and follow this policy, and will be given acceptable and regular training on it, and issues of data security on hard copy and digitally.

You must make sure that you read and understand this policy clearly. The prevention, detection and reporting of data security is the responsibility of those working for us or under our control. If you believe or suspect that a conflict with this policy has occurred, you are required to inform a director as soon as possible.  If there are any issues or suspicions of data leaking in any parts of our business, you should raise concerns.

If you are a user of such information, you need to be sure that you are not breaching any data protection rules when you store or use information and when you write and send emails. This includes but is not limited to:

  • Using data which has not been kept up-to-date. 

  • Passing on or processing personal information about an individual without their consent. 

  • Keeping personal information longer than necessary.

  • Sending personal information outside the country. 

If any breach of data protection rules is discovered, such as the leaking or hacking of personal or sensitive data, this should be reported immediately to Catherine, and any immediate action should be taken to close down such leaks. Catherine will ensure this is properly investigated and the appropriate reporting actions taken if necessary. 

Employees can request access to the information held on them by us. All requests by employees to gain access to such records should be made in writing although this includes via e-mail.