Data Security Policies

CRISCO CONSULTING takes data security extremely seriously, and we place the rights of the individual and regulatory adherence at the heart of everything we do as a company. In light of our commitments, it is mandatory all staff members must observe and adhere to the following data security policies:

Data Storage Policy

• All information or data that is collected and processed is subject to all of the applicable requirements as outlined and documented within this policy. This includes information collected electronically, by paper, telephone or data collected through any other means.
• All data must be collected, stored and protected in a secure location appointed by CRISCO CONSULTING, for a retention period as predefined by corresponding legislature or company policy.
• Staff members are strictly forbidden to retain confidential information or personal data not relating to themselves on their personal devices. Exceptions to this policy include information that is needed for a purpose that is work-related, temporary and specified and approved by a relevant manager.
• Staff members should avoid downloading sensitive files or confidential information to local devices wherever possible. Information being necessarily processed for work purposes may be exempt from this policy.
• Employees must install and use software and systems that have been licensed and approved by the company on devices while carrying out the duties of their role. Downloading or using any software, app or system that is not preapproved by the company will require prior approval from the company’s IT Manager.
• All mobile and portable devices used by staff members should be approved by the company’s IT Manager and secured to prevent unauthorised access or breach. Personal devices could include a laptop, smartphone, tablet or any other handheld computing devices. This policy also applies to any shared cloud storage spaces.
• All internet access and online operations carried out by employees could be subject to monitoring and filtering in accordance with relevant legislation and company policy. This monitoring should be carried out only by the IT Manager or an authorised member of staff.
• Employees must adhere to all applicable elements of this policy when using personal devices to access company resources. Similarly, employees must observe and adhere to all applicable elements of this data security policy when using equipment provided by CRISCO CONSULTING to access information externally.
• Employees are forbidden from using public access devices. This practice is

Allowed in some circumstances; however, prior and explicit approval from a line manager for regular public access must be obtained and recorded.

• Employees must use access tools provided to them by a client or partner of CRISCO CONSULTING if access is granted to any third-party storage system or data storage facility.
• It is forbidden to send, forward or submit any of the information or data referred to within this data security policy to a third-party unless deemed essential to complete approved processes.
• If an employee needs to carry out an approved submission of data to any relevant third-party, that data must be made secure in accordance with company policy and any relevant third-party data protection protocols.

Please note that CRISCO CONSULTING will carry out regular system audits to monitor and ensure ongoing compliance with this data security policy and all regulatory requirements as outlined under GDPR.

Data Retention Policy

While CRISCO CONSULTING must routinely collect and store data, we are committed to the rights of individuals. That’s why we retain all information and personal data for no longer than we need to. The necessary length of retention will often be decided on a case-for-case basis, bearing in mind the rationale and original purpose surrounding data collection and retention. Decisions of this nature must be made in a way that is compatible with our existing data retention guidelines under GDPR. For additional guidance, consult the following corresponding documents:

• Data retention and erasure policy document

International Data Transfer Policy

Employees must observe a series of restrictions that apply towards the international transfer of data or personal information. Employees are not permitted to transfer personal information or data outside of the United Kingdom without having obtained explicit permission in the first instance from the company’s Data Protection Officer.

Data Encryption and Anonymisation Policy

CRISCO CONSULTING deploys encryption to secure and protect data that is stored on devices from unlawful processing or unauthorised access. Encryption is also used to protect information that is in transit. We also use the anonymisation of personal data wherever deemed prudent to ensure the rights of the individual are fully protected and observed. In line with these principles, we are committed to the use both encryption and anonymisation as a risk management tool alongside existing systems, to protect the

Activities that are prohibited

Unless otherwise noted or informed, employees are strictly forbidden from using company equipment, tools or systems for any purpose unrelated to their role responsibilities, excluding any previously mentioned exceptions. This policy also relates to any relevant systems, tools or equipment belonging to a company client or partner. Bearing that in mind, the following activities should be deemed forbidden with no exceptions:

• Any unauthorised replication of copyrighted materials.
• The violation of individual rights by way of the unnecessary collection, storage and processing of personal data or information.
• The violation of rights of an individual or organisation protected under intellectual property law in any jurisdiction.
• The use of any programme, command or interface designed to interfere with a user or corresponding user session.
• The accessing of any data, user account or server for any purpose unrelated to the business function of an individual’s company role.
• Issuing fraudulent product or service offers from a company account.
• The allowed sharing or use of employee login credentials or company systems by anyone apart from the named individual.
• The export of proprietary or confidential information as it relates to the company.
• The export of any software or data that is in breach of regulation or the company’s data security policy.
• Knowingly causing a network disruption or security breach.
• An employee is not allowed to access data that is not intended for them by logging into a system or gaining access to a confidential or limited-access account. The only exception to this rule is if the employee is granted access as part of a specific company project.

Please note that any violation of this policy can lead to disciplinary action, alongside legal action where deemed prudent or necessary.

Reporting Security Issues

If you encounter any incidents or issues relating to the security or protection of information or data, you must report this immediately to company management. Management will subsequently take and record any action deemed necessary to prevent damage or loss in relation to a security threat. If necessary, it is the responsibility of company management to report relevant incidents relating to a data breach or information security threat to regulators or the authorities. Under GDPR, it also falls upon management to contact the individuals involved in any breach or security threat.