Data Protection Policy

Last updated: 11th October 2017

Croftsware (“the Company”) uses personal data about living individuals for the purpose of general administration and communication. Croftsware operates SheepCRM (“Sheep” or “the Service”) a flexible and easy to use CRM.

The company recognises the importance of the correct and lawful treatment of personal data. All personal data, whether it is held on paper, on computer or other media, will be subject to the appropriate legal safeguards as specified in the Data Protection Act 1998.

The Company recognises The General Data Protection Regulation (GDPR1) (Regulation (EU) 2016/679) adopted 27 April 2016, the two-year transition period and the application date of 25 May 2018 and is actively working towards compliance with that directive.

The Company fully endorses and adheres to the eight principles of the Data Protection Act. These principles specify the legal conditions that must be satisfied in relation to obtaining, handling, processing, transportation and storage of personal data. Employees and any others who obtain, handle, process, transport and store personal data for the Company must adhere to these principles.

  • Data Controller: James Webster
  • Data Protection Officer: James Webster

Users of Sheep

This policy sets out how Croftsware protects its own data. As a Sheep customer you are the data controller in respect of personal data you store on Sheep, it is your responsibility to ensure compliance with the data protection law of your home country. The Company has no rights to any data that you choose to upload or store. The Company will only access your data for the purpose of delivering the Service or to assist with the resolution of technical support issues or other issues relating to the Service,


The Principles

Schedule 1 to the Data Protection Act lists the data protection principles in the following terms:

  1. Personal data shall be processed fairly and lawfully and, in particular, shall not be processed unless – (a) at least one of the conditions in Schedule 22 is met, and (b) in the case of sensitive personal data, at least one of the conditions in Schedule 33 is also met.

  2. Personal data shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.

  3. Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.

  4. Personal data shall be accurate and, where necessary, kept up to date.

  5. Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

  6. Personal data shall be processed in accordance with the rights of data subjects under this Act4.

  7. Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.

  8. Personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

Source: ICO

Our legal bases for processing your personal information are:

  • consent you have given
  • processing necessary for the performance of a contract with you or to take steps to enter into a contract.

Lawful Purpose

The Company will use your data for five main purposes:

  • Verify your identity
  • Internal record keeping; e.g. supporting you in your use of Sheep, maintaining financial records, records of previous conversations
  • We may use the information to improve our products and services.
  • We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
  • From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or text message. We may use the information to customise the website according to your interests.

Applying the principles

  • All staff and volunteers who process Personal Data on behalf of the Company will be required to agree to sign our Data Processor agreement.
  • The board appoints the Data Protection Officer. All questions and concerns in relation to this policy should be addressed to them.
  • When personal information is collected we will ensure that
    • this information is necessary for the company purposes
    • the information is not kept for longer than it is needed
    • those people supplying the information are aware of this policy and how they can obtain a copy
  • Personal information (including photographs) of individuals will not be published on our website without obtaining explicit and informed consent from the individuals concerned.
  • A copy of this policy will be on our website.
  • All personal information held by staff and volunteers on behalf of the Company will be held and processed in a sufficiently secure manner (whether in paper or electronic form) to prevent unauthorised access (whether by unauthorised staff or third parties). This means we will:
    • Store paper based information in secure, lockable cabinets
    • Use password protections and encryption of particularly sensitive electronic documents (all computers used to store sensitive information must be encrypted, any mobile devices capable of accessing sensitive information must use a keyboard lock)
    • Restrict access to both paper and electronic personal data to those who need to process it for one of the above uses
    • Ensure that personal information is transmitted securely in a way that cannot be intercepted by unintended recipients
  • The Company may authorise a third party subcontractor to process the personal data on its behalf provided that the subcontractor’s contract with the Company provides equivalent rights to the those set out in this policy.
  • Personal data shared with the Company through the use of Sheep will be deleted upon termination or expiry of the contract. The Company has a comprehensive, redundant backup policy. Personal data is not removed from archived backups.
  • All personal data held in Sheep is stored within the European Economic Area (“EEA”).
  • The Company utilises third party providers (for example to manage email lists or provide interactive support) which may collect data that may be transferred to, and stored at, destinations outside the European Economic Area (“EEA”). All third party services are vetted. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Maintaining Confidentiality

The Company will treat all your personal information as private and confidential and not disclose any data about you to anyone other than the authorised staff and contractors in order to facilitate the administration and day-to-day operation of the Company.

Exceptions

There are four exceptional circumstances permitted by law:

  1. Where we are legally compelled to do so.
  2. Where there is a duty to the public to disclose.
  3. Where disclosure is required to protect your interest.
  4. Where disclosure is made at your request or with your consent.

Third-parties

You are responsible for transfer of Your data to third-party applications

The Service may allow you, the User, within the relevant subscription to Sheep to transfer data, including your personal information, electronically to and from third-party applications. Sheep has no control over, and takes no responsibility for, the privacy practices or content of these applications. You are responsible for checking the privacy policy of any such applications so that You can be informed of how they will handle personal information.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

further reading

Breach Notification

A notifiable breach will be reported to the relevant supervisory authority within 72 hours of the Company becoming aware of it. Where a breach is likely to result in a significant risk to the rights and freedoms of individuals The Company will notify you the User. Where there is a high risk the individuals concerned will be contacted directly.

Rights to Access Information

Employees and other subjects of personal data held by the Company have the right to access any personal data that is being held in certain manual filing systems (subject to certain exemptions).

  • Subject Access - all individuals who are the subject of personal data held by the Company 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 what the Company is doing to comply with its obligations under the 1988 Data Protection Act or GDPR.
  • Personal Information may be withheld if the information relates to another individual.
  • Subject Consent - The need to process data for normal purposes has been communicated to all data subjects. In some cases. If the data is sensitive, for example, information about health, race or gender, express consent to process the data must be obtained.

Any person who wishes to exercise this right should make the request in writing to the Company Data Controller, using the standard letter which is available on line from www.ico.gov.uk

The Company reserves the right to charge the maximum fee payable for each subject request. If personal details are inaccurate, they can be amended upon request.

The Company aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 40 days of receipt of a completed form unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual making the request.

Changes to this policy

The Company may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. By using the Service after the date we make any changes, you are agreeing to the changes.

Where significant changes are made to this policy older versions are made available for reference:

Footnotes

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