Information security
1. About this policy
1.1 During the course of our activities we, Tiny Spark (part of the Istoria Group), will process personal data (which may be held on paper, electronically, or otherwise) about users of our products or services that we have created for commercial purposes for agencies within the Istoria Group or for our clients and we recognise the need to treat it in an appropriate and lawful manner, in accordance with the Data Protection Act 1998 (DPA). The purpose of this policy is to make you aware of how we will handle your personal data.
2. Data protection principles
2.1 We will comply with the eight data protection principles in the DPA, which say that personal data must be:
1 Processed fairly and lawfully.
2 Processed for limited purposes and in an appropriate way.
3 Adequate, relevant and not excessive for the purpose.
4 Accurate.
5 Not kept longer than necessary for the purpose.
6 Processed in line with individuals’ rights.
7 Secure.
8 Not transferred to people or organisations situated in countries without adequate protection.
2.2 “Personal data” means recorded information we hold about you from which you can be identified. It may include contact details, other personal information, photographs, expressions of opinion about you or indications as to our intentions about you. “Processing” means doing anything with the data, such as accessing, disclosing, destroying or using the data in any way.
3. Fair and lawful processing
3.1 We will usually only process your personal data where you have given your consent or where the processing is necessary to comply with our legal obligations. In other cases, processing may be necessary for the protection of your vital interests, for our legitimate interests or the legitimate interests of others. The full list of conditions is set out in the DPA.
4. How we are likely to use your personal data
4.1 As part of a product or service you have given explicit permission to use your personal data. The specific use will be outlined as part of the terms and conditions and privacy policy for said product or service.
4.2 We may process sensitive personal data in order to comply with legal requirements and obligations to third parties.
5. Processing for limited purposes
We will only process your personal data for the specific purpose or purposes notified to you or for any other purposes specifically permitted by the DPA.
6. Adequate, relevant and non-excessive processing
Your personal data will only be processed to the extent that it is necessary for the specific purposes notified to you.
7. Accurate data
We will keep the personal data we store about you accurate and up to date. Data that is inaccurate or out of date will be destroyed. Please notify us if your personal details change or if you become aware of any inaccuracies in the personal data we hold about you.
8. Data retention
We will not keep your personal data for longer than is necessary for the purpose. This means that data will be destroyed or erased from our systems when it is no longer required.
9. Processing in line with your rights
You have the right to:
1 Request access to any personal data we hold about you.
2 Prevent the processing of your data for direct-marketing purposes.
3 Ask to have inaccurate data held about you amended.
4 Prevent processing that is likely to cause unwarranted substantial damage or distress to you or anyone else.
5 Object to any decision that significantly affects you being taken solely by a computer or other automated process.
10. Data security
10.1 We will ensure that appropriate measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
10.2 We have in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. We will only transfer personal data to a third party if you agree to comply with those procedures and policies, or if you put in place adequate measures yourself.
10.3 Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal data.
11. Providing information to third parties
Should we hold your personal data, we will not disclose your personal data to a third party without your consent unless we are satisfied that they are legally entitled to the data. Where we do disclose your personal data to a third party, we will have regard to the eight data protection principles.
12. Subject access requests
If you wish to know what personal data we hold about you, you must make the request in writing.
13. Breaches of this policy
If you consider that this policy has not been followed in respect of personal data about yourself or others that has been processed by us via our products or services, please get in touch.