DATA PROTECTION POLICY

(Part of Burly Institute of Global Education & Research Pvt Ltd)

Title

Data protection policy

Process Ownership

President HR & Strategic Affairs

Created

01 Aug, 2019

Learning Delivery Function

Approval Body

Chairman IIMT Studies Ltd. UK

Review Date

01 Jul, 2021

Learning Delivery Function

Approval Body

Chairman IIMT Studies Ltd. UK

Version 2

30 Aug 2021 To 01 Jul, 2022

Learning Delivery Function

Approval Body

Chairman IIMT Studies Ltd. UK

Version 3

30 Aug 2022 To 01 Jul, 2023

Company number :	U80900GJ2017PTC097640 ( Burly Institute of Global Education & Research Pvt. Ttd.)
Registered office address :	9-10 Floors, Annexie Wing, Pariseema Complex, C G Road, Ahmedabad- 38009 ( India)

Policy Statement

During our establishment and operational activities, Burly Institute of Global Education & Research Pvt Ltd. (IIMT Studies) collects and uses data about a wide range of individuals, including staff, students, candidates, and external visitors. It is essential to maintain the security and privacy of their personal data. Data protection law assures how their personal data must be kept private, maintained, processed and used in relation to its owners’ rights. This policy is drafted considering the new Data Protection Act 2018 and the implementation of the EU General Data Protection Regulations 2016 (‘GDPR’).

IIMT Studies has policies in place, including this policy, which is designed to protect the accuracy, integrity, and confidentiality of Personal Data and ensure that individuals can exercise their rights to comply with the law.

This policy applies to IIMT Studies staff, learners, stakeholders, external associates, staff members and all other associates. The policy is also applicable in development, delivery and award of qualifications, including external assessments conducted by and e-portfolio of learners. Any agency on behalf of IIMT Studies.

Objectives of policy:

This data protection policy ensures IIMT Studies:

Complies with data protection law and follow good practice
Protects the rights of employees, learners, and third-party partners
Is open about how it stores and processes individuals’ data
Protects itself from the risks of any data breach

Data protection law:

The Data Protection Act 1998 describes how IIMT Studies, must collect, handle and store personal information.

Data protection law applies regardless of whether data is stored electronically, on paper or any other form of materials.

In order to comply with the Data protection law, any information or personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The below important principles underpin the Data Protection Act. Where 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 European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

Policy scope:

The policy applies to all employees employed by IIMT Studies, including honorary staff/associates, contractors, hourly paid contractors and any learners, interns or volunteers or any third party contractual agency who are carrying out work on behalf of the IIMT Studies.

Data protection risks:

This policy helps to protect IIMT Studies, from some very real data security risks, including:

Breaches of confidentiality. For instance, information being shared out of IIMT Studies 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 IIMT Studies has some responsibility for ensuring data is collected, stored, and handled appropriately and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

The Board of Directors is ultimately responsible for ensuring that IIMT Studies, meets its legal obligations.
The Chief Executive Officer is responsible for:
- Keeping the board updated about data protection responsibilities, risks, and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
The Human Resource Executive is responsible for:
- Handling data protection questions from employees and anyone else covered by this policy.
- Dealing with individuals’ requests to see the data IIMT Studies, holds about them (also called ‘subject access requests’).
The IT manager / Department /Data Protection Officer is responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards
- Performing regular checks and scans to ensure security hardware and software is functioning properly
- Evaluating any third-party services, the company is considering using to store or process data—for instance, cloud computing services.
The Marketing is responsible for:
- Approving any data protection statements attached to communications such as emails and letters.
- Addressing any data protection queries from journalists or media outlets like newspapers.
- Where necessary, working with other employees to ensure marketing initiatives abide by data protection principles.
General employee guidelines:
The only people able to access data covered by this policy should be those who need it for their official work to carry out tasks assigned as a part of KRAs .
Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers or HR Department.
IMT Studies 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.
Strong passwords must be used (8 letters minimum, alpha numerical with one special character ), and they should never be shared. For any documents encrypted with a password, the password should only be shared with whom the data is required to be shared, and there should be a valid purpose in this instance
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, with appropriate permission of IT Function or Manager.
Employees should request help from their line manager or the HR Department if they are unsure about any aspect of data protection.

Data storage:

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager/ IT Department.When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed for some reason:

When not required, the paper or files should be kept in a locked drawer or filing cabinet.
Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion, and malicious hacking attempts:

Data should be protected by strong passwords that are changed regularly and never shared between employees.
If data is stored on removable media (like a CD or USB Drive), these should be kept locked away securely when not being used.
Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing service.
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 smartphones, not belong to IIMT Studies.
All servers and computers containing data should be protected by approved security software and a firewall.
Such firewalls must be approved by IIMT Studies.

Data use:

Personal data is of no value to IIMT Studies, unless the business can make use of it. However, it is when personal data is accessed & 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 may not found secured.
Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
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 IIMT Studies to take reasonable steps to ensure data is kept accurate & up to date.

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. Employees should not create any unnecessary additional data sets.
Employees should take every opportunity to ensure data is updated, for instance, by confirming a student’s details when they call.
IIMT Studies will make it easy for data subjects to update the information IIMT Studies, holds about them. For instance, via the company website.
Data should be updated as and when inaccuracies are discovered. For instance, if a student can no longer be reached on their stored telephone number, communication email addresses, it should be replaced from the database with correct data .
It is the marketing manager’s responsibility to ensure marketing databases are checked every month before closing the business month of their teams.

Subject access requests:

All individuals who are the subject of personal data held by IIMT Studies are entitled to:

Ask what information the Institute holds about them and why.
Ask how to gain access to it.
Be informed on how to keep it up to date.
Be informed about how the Institute is meeting its data protection obligations.

If the individual contact the office requesting this information, this is called a subject access request. Subject access requests from individuals should be made in writing, addressed to the HR Department. The Department can supply a standard request form, although individuals do not have to use this.

Disclosing data for other reasons:

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

Under these circumstances, IIMT Studies will disclose requested data. However, every step will be taken to ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where and if necessary.

Providing information:

IIMT Studies 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

This policy forms a part of a broader Governance Framework with other policies and procedures of IIMT Studies. Compliance with these is mandatory, and any breach of the requirements contained in these documents may result in disciplinary action.