Data Protection Policy

Policy became operational on: 1 April 2020

Next review date: 1 April 2021

Introduction

ID Analyzer operated by Evith Technology Ltd. needs to gather and use certain information about individuals. This policy governs the data submitted to our company during the use of our service ID Analyzer, for website and cookie related privacy policy please refer to this page instead.

These can include customers, third-party personal information submitted by our customers in relation to using our services, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

ID Analyzer is a service provided by Evith Technology that processes highly sensitive personal data on-behalf of our customers, this data protection policy ensures that the company Evith Technology:

Complies with data protection law and follow good practice
Protects the rights of staff, customers, and partners
Is open about how it stores and processes individuals’ data
Protects itself from the risks of a data breach

Data protection law

The General Data Protection Regulation 2016/679 describes how organisations — including Evith Technology — must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The General Data Protection Regulation is underpinned by eight important principles. These say that personal data must:

Be processed fairly and lawfully
Be obtained only for specific, lawful purposes
Be adequate, relevant and not excessive
Be accurate and kept up to date
Not be held for any longer than necessary
Processed in accordance with the rights of data subjects
Be protected in appropriate ways
Not be transferred outside the EU, unless that country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope

This policy applies to:

The head office of Evith Technology
All branches of Evith Technology
All staff and volunteers of Evith Technology
All contractors, suppliers and other people working on behalf of Evith Technology

It applies to all data that the company holds relating to living individuals, even if that information technically falls outside of the General Data Protection Regulation 2016/679. This can include:

Names of individuals
Postal addresses
Email addresses
Telephone numbers
…plus any other information relating directly or indirectly to individuals

Data Protection Risks

This policy helps to protect Evith Technology from some very real data security risks, including:

Breaches of confidentiality. For instance, information being given out inappropriately.
Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with Evith Technology has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

General staff guidelines

The only people able to access data covered by this policy should be those who need it for their work.
Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
Evith Technology will provide training to all employees to help them understand their responsibilities when handling data.
Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
In particular, strong passwords must be used and they should never be shared.
Personal data should not be disclosed to unauthorised people, either within the company or externally.
Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
Employees should not carry any physical storage device to work that is capable of saving any personal data. Nor should any employee utilize internet or other communication method to share any personal data with third-party.

Data Storage

We understand it is a major privacy concern for your business when using ID Analyzer service as it requires uploading of sensitive personal information for us to provide the service. We have designed a highly secured system to ensure the privacy of our customers and their users. To disable personal information logging while accessing ID Analyzer service, it is possible to specify a parameter "vault_save" when submitting document to our API system. By setting the parameter to the value "false", all personal information including images uploaded, request parameters and response result will be permanently deleted from our server upon completion of the API request. No data containing any personal information will be stored if you specify this special parameter, with the exception of HTTP log file which contains only your server IP address connecting to our API, user agent header and a timestamp.

In case where vault storage is not disabled, document submitted to our API will be stored in our secured vault system, which is made available only to you under your Web Portal, entries inside the vault can be permanently deleted at any time.

These rules describe how and where data should be safely stored.

Data should be protected by strong passwords that are changed regularly and never shared between employees.
Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
Servers containing personal data should be sited in a secure location, away from general office space.
Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
All servers and computers containing data should be protected by approved security software and a firewall.
All servers that stores data should reside in a country that is deemed to have adequate level of protection by the European Commission.

Data Use

For us to improve ID Analyzer service and provide support to our customers, it is necessary for our company to work with customers' data, we do so under an environment governed by strict guidelines. We understand when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
Personal data should never be transferred outside of the company’s local area network, unless requested by a verified customer.
Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data Accuracy

The law requires Evith Technology to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort Evith Technology should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
Evith Technology will make it easy for data subjects to update the information Evith Technology holds about them. For instance, via the company website.
Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject Access Requests

All individuals who are the subject of personal data held by Evith Technology 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 how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at [email protected] The data controller can supply a standard request form, although individuals do not have to use this.

Individuals cannot be charged to honour a subject access request. The data controller will aim to provide the relevant data within 30 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing Data for Other Reasons

In certain circumstances, the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Evith Technology will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing Information

Evith Technology aims to ensure that individuals are aware that their data is being processed, and that they understand:

How the data is being used
How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.