Introduction

The General Data Protection Regulation (GDPR) is a new legal framework set up by the European Union in April 2016 to build upon existing data protection legislation. GDPR came into effect on 25^th May 2018, and has introduced a range of fresh guidelines spelling out the rights of consumers and dictating how companies can store and share information.

As a hugely significant change to the global business landscape, it is critical that KC Multimedia Ltd embraces all aspects of GDPR to maintain full compliance.

Our obligations for GDPR compliance

Here at KC Multimedia Ltd, we fully appreciate and support the European Union’s focus on expanding upon digital rights. As a company, we strongly believe in the need for greater business transparency and accountability concerning the collection and handling of personal data.

That is why KC Multimedia Ltd is a firm advocate of GDPR and its many implications. These include among many other aspects:

• The Right to Object to Processing
• The Right to Be Forgotten
• The Right to Data Portability
• The Right to Withdraw Consent

As part of our commitment to GDPR and the rights of our customers and clients, KC Multimedia Ltd vows to ensure our organisation considers and actions all necessary changes surrounding data processing, data storage and the disposal of personal data.

This includes a commitment to fully fulfil Breach Disclosure Requirements by notifying authorities and concerned individuals of any compromise within 72 hours. Moreover, as part of our GDPR strategy, KC Multimedia Ltd will complete impact assessments wherever possible, to identify and deliver the best service possible, as well as to extend our customers a guarantee that data is being kept secure.

Furthermore, we pledge to uphold the following key values and responsibilities:

• We vow to demonstrate full responsibility and dutiful respect as a keeper of customer, client and employee data.
• We totally support GDPR and its requirements, and will do everything within our power to appropriately resource and fund any changes we must enforce to ensure KC Multimedia Ltd can meet its obligations.
• We promise to maintain ownership and transparency concerning data protection and privacy across all elements of our company.
• We pledge to create and maintain a purposeful data processing inventory documenting all data operations, including collection, processing and storage.
• We guarantee to extend every possible show of support to individuals intent on exercising their rights as outlined under GDPR legislation.
• We will conduct a regular review to assess the legality and purpose for the collection, processing and storage of personal data.
• We vow to act upon identified gaps and develop robust processes to maintain full GDPR compliance.
• We promise to clearly communicate the business purpose and legal grounds for any transfer of data – including transfer outside of the European Union.
• We will contact all partner organisations, contractors or other third parties to identify their own GDPR commitments, establish relevant contract terms and solidify GDPR compliance controls.

Introduction

Here at KC Multimedia Ltd, we collect, process and store personal data for a range of business purposes. Data subjects include customers, suppliers, partners, employees, clients and other stakeholders and individuals.

Bearing in mind KC Multimedia Ltd’s commitment to uphold the rights of the individual as enshrined in law, our data security policy is designed to protect all past, current and future employees, customers, or partners, from illegal or damaging activity conducted by others using their personal data.

Our data security policy outlines how KC Multimedia Ltd will endeavour to guard and protect all personal data. It also sets out to raise the awareness of staff members in relation to the ways in which GDPR impacts their use of individual’s personal data.

This policy applies to all data processing activities involving KC Multimedia Ltd, and includes activities or systems related to both internal business operations, as well as external relations and any third-party agreements.

Please note that KC Multimedia Ltd’s data security policy applies to all employees, and this policy may be subject to review and amendment on a regular basis. For more information about this policy and its overall implementation, consult our Data Protection Officer.

This document is subject to regular review to ensure ongoing regulatory compliance.

Data security policy definitions

Personal data

Personal data encompasses any type of information that relates to an identifiable individual. Various types of personal data KC Multimedia Ltd may collect, store and process could include:

• Contact details
• Financial information
• Educational background
• Certifications
• Skills
• Nationality
• Marital status
• Job title

The above list is by no means exhaustive, and should be used merely as a point of reference from which a working definition of personal data can be established and further developed.

Sensitive personal data

Under GDPR, sensitive personal data is defined as encompassing any of the following:

• Racial or ethnic origin
• Political opinion
• Religious or philosophical beliefs
• Trade union membership
• Genetic data
• Biometric data
• Health-related information
• Sexual orientation

It is paramount that all sensitive personal data is kept under stringent control as part of the implementation of our data security policy.

Purposes of personal data

KC Multimedia Ltd uses personal data for a range of various purposes. These purposes may include:

• Financial
• Administrative
• Human resources
• Regulatory compliance
• Payroll
• Business development

Please note the above list is by no means exhaustive, and should merely be used as a reference point from which a working definition of purpose can be established.

Business purposes

KC Multimedia Ltd must carry out a range of functions and processes as part of our operational activity. Data kept in relation to these activities falls under the category of data for business purposes, which includes information of the following nature:

• Operational
• Compliance
• Policy adherence
• Human resources and personnel
• Marketing

The above list is by no means exhaustive, and should be used merely as a point of reference from which a working definition of business purposes can be established and further developed.

Fair processing

At KC Multimedia Ltd, there will be occasions when employees will need to process personal data; however, processing activities must always be carried out in a fair and lawful manner that is compatible with the rights of each corresponding individual. Consequently, we should avoid processing the personal data of any individual who has not provided us with explicit consent.

Our company must strive to obtain explicit consent at all costs, and we must clearly identify to the individual what data is being processed, why we need to use it and who will have access to their data. These factors must be identified and clearly reiterated to the individual at the point of request for consent.

It’s worth noting there may be exceptional circumstances in which we are asked to process sensitive personal data without consent. An example of an exceptional circumstance could include legal obligations we may need to carry out to comply with health and safety regulations.

KC Multimedia Ltd endeavours to take all actions necessary to ensure that all personal data we obtain, process and store is accurate, relevant and adequate in relation to the reason in which we asked for that information. We should not hold excessive or irrelevant data on any individuals, and we will not process any personal data for a purpose unrelated to the purpose in which the relevant individual has consented to the processing of their data.

Our roles and responsibilities

Data security is a critical component of our business. It falls on everyone at KC Multimedia Ltd to take responsibility for data security, and all employees must familiarise themselves with our data security policy and do everything within their power to uphold that policy on a day-to-day basis.

Please note that KC Multimedia Ltd takes data protection incredibly seriously, and we expect all staff members to adhere to this data security policy. Any failure and refusal to comply with this policy could ultimately place our company at risk.

Bearing that in mind, personal non-compliance with this data security policy could lead to disciplinary action as they relate to ordinary personnel procedures. Please contact your line manager with any further questions concerning data protection at KC Multimedia Ltd.

As a staff member at KC Multimedia Ltd, you can expect to receive data protection training in line with our data security policy. All incoming employees will be provided training as an aspect of the wider staff induction process, and all staff members can anticipate the requirement to undergo additional training as a result of subsequent regulatory updates to GDPR or other relevant legislation as it relates to data security.

Data security will inevitably encompass a range of additional responsibilities for various roles within the company. These roles and their responsibilities include (but are not limited to):

Data Protection Officer

GDPR stipulates our company must appoint a Data Protection Officer. It is our Data Protection Officer’s responsibility to:

• Organise data security training for all employees not specifically referenced within this data security policy.
• Review and analyse all existing data security protocols and processes on a regular basis.
• Be a point of contact for all employees, clients and stakeholders to answer questions about data protection and data security.
• Respond to internal or external queries from individuals wanting to know what data relating to them may have been obtained, processed or stored by our company.
• Conduct due diligence and submit approval in relation to any contractual agreement with a third party involving the processing or storage of data.
• Maintain constant contact with company directors, board members and stakeholders in relation to data security, company responsibilities and data risk management.

IT Manager

Information technology plays a crucial role in the way our company operates. Any processes relating to IT and the processing and storage of data must be carefully monitored, assessed and guided by an IT Manager.

It is the responsibility of KC Multimedia Ltd’s IT Manager to:

• Conduct due diligence and appropriate levels of research into any third-party service that our company may call upon to store or process any data.
• Make sure that all company software, IT systems, equipment and services meet changing levels of data security standards.
• Carry out regular checks, audits and scans to ensure security hardware and security software are fully functional and optimised to manage and mitigate data security risks.

Marketing Manager

A significant proportion of our marketing activities involve the collection, storage and processing of data. Consequently, our Marketing Manager must oversee the following responsibilities:

• Accept all queries relating to data security and data protection from leads, media outlets, clients or other individuals and oversee and deliver an adequate response.
• Work alongside KC Multimedia Ltd’s Data Protection Officer to make sure that all of our marketing processes, campaigns and activities are compliant with all relevant data security and data protection laws – as well as our own company data security policy.
• Review, draft and approve any relevant data security statements that must accompany emails, other messages or applicable marketing collateral.

Our data security policies

KC Multimedia Ltd 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 KC Multimedia Ltd, 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 KC Multimedia Ltd 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 KC Multimedia Ltd 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 KC Multimedia Ltd 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 KC Multimedia Ltd 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

KC Multimedia Ltd 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 company from accidental loss, as well as from the damage or destruction of data or personal information.

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.

KC Multimedia’s Data Protection Notice

KC Multimedia Ltd collects, processes and stores the information and personal data you submit to our website in relation to carrying out our day to day business activities. All processing activities shall be carried out in accordance with your individual rights as defined by the European Union’s General Data Protection Regulation.

Please note that by submitting information about yourself through our website, you are agreeing for KC Multimedia Ltd to process and store that data. This data shall be stored only for the duration of the previously outlined purpose for collection. We never store or process your data longer than we need to, and we do not use your data for any purpose other than those you have agreed to.

The data you submit to our website will never be shared with or transferred to a third-party organisation. The following partners are exempt from this policy as they assist KC Multimedia Ltd in processing your personal data and delivering its services; PayPal, GoCardless, Stripe and WorldPay.

You reserve the right to request KC Multimedia Ltd update your personal data at any time. You can also request information about your personal data, withdraw your consent for us to process your information or request a transfer or deletion of your data.

For more information about KC Multimedia Ltd and how we protect and secure your data, consult our Privacy Notice and Consent below.

Please tick this box to indicate you have read and consent to our Privacy Notice:

1. Policy introduction

Here at KC Multimedia Ltd, we are committed to data security, the privacy of the individual and upholding all our compliance obligations under GDPR. We take our responsibilities seriously, and we recognise that the use of information assets and data form a crucial aspect of our business activity. That is why we’ve devised the following Data Classification Policy to outline the way in which we classify and use data.

Our Data Classification Policy is designed to ensure that:

• KC Multimedia Ltd adheres to all necessary legal obligations
• We implement controls to maximise return on investment
• KC Multimedia Ltd maintains availability, confidentiality and integrity where necessary for all data
• Our company has the ability to chart data protection levels that protect both KC Multimedia Ltd as well as the individuals whose personal data we must collect, process or store
• We are able to avoid threats of disclosure and/or unauthorised access to data

2. Policy values

Data classification is a vital process our company must carry out to ensure the individuals who claim a legitimate right to access information we hold are able to do so. Our data classification process must also ensure our data and any other piece of information we hold is protected from any and all individuals or organisations that should not have access to that information.

KC Multimedia Ltd’s Data Classification Policy identifies and elaborates upon the correct handling and classification processes our company must use, as per the regulatory requirements that we:

• Make data available to all those individuals who have a legitimate reason to access it
• Manage all data in line with its corresponding classification
• Maintain the integrity of all data
• Ensure all data our company holds is accurate, complete and consistent

3. Policy objectives

KC Multimedia Ltd’s Data Classification Policy has been developed to meet the following objectives:

• To outline the duties and responsibilities of KC Multimedia Ltd employees that ensure data is kept safe and secure
• To establish a robust data classification process that is consistent and compliant with UK regulatory requirements
• To ensure data is sufficiently protected and encrypted so that unwarranted actions will not be taken against KC Multimedia Ltd in the event data is lost, damaged or accessed illegally
• To avoid and minimise reputational or operational damage to KC Multimedia Ltd, our stakeholders, clients, customers or partners associated with compromised data

4. Policy implementation

To make sure our Data Classification Policy is effective, KC Multimedia Ltd will implement the following procedures:

• All users of data will be identified and provided access to data in which they have a legitimate need to access
• All data will be classified, managed and controlled in relation to its correct categorisation, as per the processes and requirements outlined within this policy
• KC Multimedia Ltd must ensure control mechanisms are created and implemented to protect data we collect, process or store
• All control mechanisms and classification protocols must be reviewed and amended as required by law on a regular basis
• Data users and data controllers must implement and maintain adequate levels of physical security as required, in relation to computer facilities or access terminals from which data can be viewed or accessed
• KC Multimedia Ltd must ensure that all data and relevant equipment is safely disposed of, as and when required

5. Obligations under GDPR (2018) and Data Protection Act 2018 (DPA)

KC Multimedia Ltd is committed to meet its regulatory obligations under GDPR and DPA. That is why we are committed to ensure that adequate and appropriate measures are taken to prevent the unauthorised access or illegal processing or storage of data. We are required to do everything we can, within reason, to protect the data we use and hold against destruction, accidental loss or damage.

6. Data classifications

Data that is sensitive in nature must be adequately protected at all times. To properly assign safeguards, all data that our company collects, processes or stores must be assigned one of the following classification categories:

• Public
• Open
• Confidential
• Strictly Confidential
• Secret

A vast amount of the data KC Multimedia Ltd uses will most likely be classed as being either ‘Public’ or ‘Open’ data. Any information relating to an individual or organisation that could identify them or is personal or private in nature must be assigned a category of either ‘Confidential’ or ‘Strictly Confidential’.

This is to ensure KC Multimedia Ltd upholds its regulatory commitment to uphold the rights of individuals, as outlined under GDPR.

On rare occasions, KC Multimedia Ltd may wish to class data as ‘Secret’. If an employee is unsure as to whether they should categorise a piece of data as being secret – or if they need assistance in classifying any other piece of data, they should consult a line manager. If no manager is available for consultation, data should default to a ‘Confidential’ classification.

7. Data classification types and handling procedures

To minimise discrepancies and ensure KC Multimedia Ltd does everything it can to uphold its regulatory commitments, the following working definitions should be associated with the aforementioned classification categories.

Public data

Public data is information or data that can be accessed by any external individual or organisation.

Types of public data might include:

• Official contact data of relevant company employees
• News updates or press releases
• Company publications
• External-facing company policies or procedures

How to handle public data:

Public data should be formatted to allow for the most basic security measures. Examples might include converting a Word document into a PDF to avoid others editing it, as this could subsequently cause some form of reputational damage.

Open

Anyone is able to access this information.

Types of open data might include:

• Official contact data e.g. full name, primary email address and telephone number
• Authorised communications, such as blogs, news articles and industry updates
• Approved company policies, guidance and processes

How to handle open data:

Open data should be formatted to allow for the most basic security measures. Examples might include converting a Word document into a PDF to avoid others editing it, as this could subsequently cause some form of reputational damage.

Confidential data

Access to confidential data must be limited only to individuals who have been granted appropriate authorisation to view or process that information.

Alternatively, there may be occasions in which unauthorised individuals or stakeholders may need to be granted access to confidential data; however, this access must only be provided on a need-to-know basis.

Types of confidential data might include:

• Someone’s personal details or any information that could be used to identify them. Examples of identifiable or personal details include:
• Name
• Date of birth
• Address
• Telephone number
• Email address
• National Insurance number
• Race
• Religion
• Health details
• Political affiliations
• Trade union membership
• Criminal offences
• Employee contracts
• Non-Disclosure Agreements
• Unfinished or unapproved company documents
• Employee wage slips
• Death certificates
• PDR documentation

How to handle confidential data:

As and where required to handle confidential data, employees should exercise the following handling processes:

Paper documents must be:

• In secure locked storage
• Transported in sealed envelopes only
• Transported by an approved third-party courier service
• Securely disposed of

Electronic data must be:

• Encrypted
• Password-protected wherever possible
• Transportation must follow secure file transfer protocol
• Storage must be limited to secure file stores
• Securely disposed of

Strictly confidential data

A minimal number of authorised individuals, authorities or other stakeholders may be permitted access to data that has been classified as being ‘Strictly confidential’.

Types of strictly confidential data might include:

• Bank details
• Credit card information
• Financial information
• Server information
• Usernames or passwords
• Test data
• Medical records
• Disciplinary proceedings
• Patent information
• Network information

How to handle strictly confidential data:

As and where required to handle strictly confidential data, employees should exercise the following handling processes:

Paper documents must be:

• In secure locked storage
• Transported in sealed envelopes only
• Transported by an approved third-party courier service

Electronic data must be:

• Encrypted
• Password-protected wherever possible
• Tagged
• Transportation must follow secure file transfer protocol
• Storage must be limited to secure file stores

Secret data

Access to data that has been classed as ‘Secret’ or a request to access secret data is subject to the Official Secrets Act.

Various types of secret data may require different controls and circumstances. Bearing that in mind, individual protocols should be reviewed on a case-for-case basis in line with UK Government requirements. Government advice concerning the handling of secret data should be sought.

8. Data classification markings

Data classification markings need to be clearly visible at all times and must match the classification category in which that data has been assigned. Appropriate data classification identification markings should be included either at the top, bottom or centre of each document page.

9. Reclassifying data

There may be occasions in which data must be reclassified from one data category to another data category. The need for reclassification could depend upon a content change, or an alteration in terms of the data’s intent, where it is stored or how it is being used. Before reclassifying data, a firm and justifiable rationale must be established. If in doubt, contact the Data Protection Officer or your line manager for guidance.

10. Sensitive data

It is the responsibility of the data owner or the data originator to define the category of data classification for a piece of data. Responsibility also rests with the data owner or originator to ensure that adequate protection has been afforded to that data in line with its relevant classification.

Any data that could or should be defined as being personal in nature must be afforded a higher level of protection and be treated as data that is sensitive. Personal data can be classed as information relating to an individual that could identify them. Aforementioned examples of sensitive personal data might include (among other pieces of data) a person’s name, contact information, race, religion, political affiliations, sexual preference and so on.

Sensitive data must be identified and assessed on a case-for-case basis. In most cases, sensitive data will inherently be classed as confidential; thus, access and/or availability must be limited.

Sensitive data which is made available in the public domain can lead to reputational damage for private individuals or company employees. As a company we must ensure that sensitive data is given sufficient protection to protect individuals, company employees and the company itself.

11. Data storage and backup

Because data is such an integral aspect of our business, it is everyone’s responsibility at KC Multimedia Ltd to do everything within their power to ensure that sensitive data is being collected, processed, backed up, stored and secured in line with company policy.

12. Data anonymisation

Prior to the sharing, transfer or disclosure of data, KC Multimedia Ltd and its employees must take all necessary steps to ensure that the anonymity of corresponding data subjects is protected and maintained in line with our regulatory commitments.

Necessary steps may include omitting or redacting (deleting) said personal identifiers within a piece of data. Audio visual data or verbally exchanged data recordings should be likewise edited.

13. Secure data disposal

Sensitive data that is no longer needed or has reached an ‘end of life’ classification as decided upon by the relevant authorised individuals must be disposed of in a secure fashion. Examples of disposing data as stored on paper would include shredding.

14. Data security response

If data is damaged or lost, it must be immediately reported to an appropriate line manager and company Data Protection Officer, and logged as an incident requiring urgent response.

Data retention and erasure policy introduction

Our approach towards data retention

This policy is designed to ensure KC Multimedia Ltd does everything within its power to adequately protect, maintain and store data. This policy has also been developed to ensure that any data, documents or records that have no further use or value to KC Multimedia Ltd are disposed of in line with our regulatory obligations and relevant company policy.

Employees should consult our data retention and erasure policy, to develop an understanding of our company’s obligations relating to the ways in which we retain data or electronic documents. These documents may include, but are not limited to:

• Emails
• Word Documents
• Spreadsheets
• PDF documents
• Web files
• Sound files
• Videos

Personal data must never be kept for longer than it is needed. Consequently, employees should utilise our company’s data retention schedule as a guide to understanding KC Multimedia Ltd’s general retention period time for various data categories that have been assigned based upon the purpose of the data. In line with our regulatory obligations, all data that is no longer necessary should be deleted and all copies must be destroyed in line with our data erasure schedule.

Data retention schedule administration

This data retention schedule documents the maintenance, retention and disposal guidelines relating to any and all records our company holds. It must be reviewed and accordingly amended on a regular basis to ensure data storage and erasure processes are adhering to KC Multimedia Ltd’s wider data retention policy approach.

There will be times when data may need to be retained longer than the pre-defined amount of time permitted. Circumstances in which our policy will need to be suspended may include, but are not limited to:

• Legal proceedings
• Regulatory investigations
• If criminal activity is suspected or alleged
• If relevant data concerns a company or organisation in receivership or liquidation
• If the relevant data is of historical importance to the owner or controller

In the event of legal proceedings, criminal activity or investigations, KC Multimedia Ltd and its employees must retain data that relates to the situation and could serve to aid the company’s case or position, liability or amount involved. If such a situation may occur during the lifetime of this policy, KC Multimedia Ltd will inform all staff of the policy’s suspension as it relates to said situation.

Data retention schedule

KC Multimedia Ltd has developed its data retention policy in line with the following data retention schedule:

1. Accounting and finance data

Any and all items that display customer bank details or credit card information must be kept under secure conditions when not in immediate use. This includes keeping printed records in a locked desk drawer or filing cabinet.

If KC Multimedia Ltd determines it is necessary to keep a document that displays customer financial details beyond a retention period of 2 years, all identifying details or financial information as it relates to any customer must be redacted or removed from the document in question.

2. Contract data

3. Corporate records

For the purpose of this schedule and corresponding policy, ‘corporate records’ should be defined to include anything relating to:

• Meeting minutes
• Signed minutes of the board
• Signed minutes of any committees
• Record of incorporation
• Articles of incorporation
• Annual corporate reports

4. Correspondence and internal memoranda

The vast majority of correspondence and internal memoranda must be retained to match the period of time as the document or data to which they relate. Examples may include an email relating to a contract – in which case the email in question would be expected to be retained for a period of 7 years after the expiration of the corresponding contract.

Bearing this in mind, KC Multimedia Ltd recommends that all correspondence and internal memoranda as it relates to a company project be kept with said project as part of a project-wide file.

Company correspondence or internal memoranda unrelated to documents that have a defined retention period, should be securely destroyed at an earlier time depending upon which of the following two categories it corresponds:

Category 1

Category 1 correspondence or internal memoranda includes any and all data as it relates to routine processes. Category 1 correspondence and internal memoranda generally do not carry any significant consequences and should be disposed of with 2 years.

Examples of category 1 correspondence and internal memoranda may include (but are not limited to):

• Notes of appreciation or thanks
• Plans for meetings
• Forms or letters that do not require a follow up
• General enquiries that have been settled
• Chronological correspondence data
• Complaints requesting a specific action that have already been addressed and carry no further value
• Correspondence relating to inconsequential subject matter

All copies of internal office correspondence should be read and destroyed as per this policy unless that correspondence includes data or content that must be retained as part of a wider project.

Category 2

Category 2 correspondence or internal memoranda includes non-routine information or correspondence that is likely to have a consequential impact upon the company or its employees. Category 2 correspondence and internal memoranda should be retained on a permanent basis.

5. Personal data

There will be times when KC Multimedia Ltd and its employees must retain and/or delete personal data in line with its legal obligations.

For the purposes of this data retention and erasure policy, ‘personal data’ can be defined as any identifying information as it relates to an individual. We never keep personal data for longer than is necessary for the purpose in which that data was collected. All personal data as defined within the following categories should be deleted based upon this retention and erasure schedule:

KC Multimedia Ltd reserves the right to retain any and all documents (both electronic and print) containing personal data to the extent our company is required by law to do. We will also retain documents containing personal data if we have reason to believe said documents could be relevant to legal proceedings, or to establish and/or exercise our own legal rights.

Our company will organise backups of our database and all of the electronic data held within our company server(s). Backup activities should include all data that relates to current users or customers, alongside any document or dataset relating to one of the aforementioned reasons as outlined within this data retention and erasure policy. KC Multimedia Ltd does this to ensure that lost information can be retrieved within one year, as and where needed.

6. Electronic data

Emails

Most emails do not need to be kept. Emails that are inconsequential or unrelated to contracts or projects should subsequently be treated in line with the following policies:

• All emails should be deleted after 12 months. This includes both internal and external emails
• KC Multimedia Ltd will archive emails for six months after employees have deleted them. After this six-month period, archived emails will be destroyed
• Employees should never send emails containing confidential or proprietary data to external sources unless it has been approved by a relevant manager

Electronic documents

Electronic documents include, among other formats, both PDF document and files originating from Microsoft Office Suite or similar software.

Retention and erasure will depend upon the purpose of the electronic document, yet as a general rule of thumb employees can apply the following rules:

For PDF documents, the maximum period of retention should be 6 years. PDF documents that employees deem vital to their performance or role should be printed and/or stored in the relevant employee’s workspace.

For text documents or other formatted files, the maximum period of retention should be 5 years. Text documents or other formatted files that employees deem vital to their performance or role should be printed and/or stored in the relevant employee’s workspace.

KC Multimedia Ltd does not and will not automatically delete electronic documents or corresponding data beyond the time periods defined within this policy. It is the responsibility of our employees to ensure they are adhering to our policy guidelines.

7. Insurance data

8. Legal data

9. Miscellaneous data

10. Personnel data

11. Tax data

KC Multimedia Ltd keeps accounts and/or records to demonstrate and establish amounts of gross income, deductions, credits and other information. These records are crucial to maintaining our company’s compliance of tax laws.

Associated records and documentation will include (but are not limited to) the following records and associated schedules:

Frequently asked questions

Privacy Notice

Date: 06 April 2022

KC Multimedia Ltd takes your privacy seriously. That is why we will only use your personal information to provide you with the products and services you have requested, as well as to administer your account. We will not sell or share your information with third-parties you grant us explicit permission to do so, and we will never use your personal data for any reason other than the reasons described within this policy.

About our privacy policy

Our privacy policy outlines your relationship with our company and explains in detail how we use the information that you provide us with.

About KC Multimedia Ltd

KC Multimedia Ltd is the trading name of KC Multimedia Ltd, which is registered in England and Wales and registered with the UK’s Information Commissioner’s Office under the Data Protection Act 2018. Our data controller is Ken Cope, and we encourage you to get in touch with any questions you may have about KC Multimedia Ltd.

You can reach us by:

• Post: 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ, UK
• Telephone: 07952 599578
• Email: info@kcmultimedia.ltd
• Website: https://kcmultimedia.ltd

Changing your preferences

If you’d like to change your web, contact or marketing preferences, you can do so at any time. Simply contact us at support@kcmultimedia.ltd to request the necessary amendments.

How we do business

KC Multimedia Ltd is committed to upholding and maintaining your personal rights. We operate our business in-line with the European Union’s General Data Protection Regulation and observe your rights to change or withdraw your opt-in options at any time. As part of our ongoing commitment to uphold your rights, KC Multimedia Ltd will also extend advice on how you can issue formal complaints to relevant authorities, such as the Information Commissioner’s Office.

Sensitive data

KC Multimedia Ltd does not collect any sensitive data about you. Sensitive data refers to (but is not limited to) information about your race or ethnic background, religious or political affiliations, trade union affiliations, sexual orientation, criminal background or health background.

Who our privacy policy applies to

This privacy policy has been developed to inform users of KC Multimedia Ltd how we use their data. KC Multimedia Ltd is a multimedia company offering website design, graphic design, webhosting and Domain Names, and we need to process the data of individuals to offer our products and/or services. Bearing that in mind, our privacy policy applies to any and all individuals registered with us as a user, customer, administrator or in any other capacity.

What information this policy applies to

There is a lawful basis for processing your data, and this section of our privacy policy outlines how this applies to the personal information you provide us with or allow us to collect.

The information this policy applies to includes information that you:

• Provide as part of any registration process
• Provide as part of any campaign creation activity
• Provide in the form of numerical data, metadata or communications
• Give us as part of our ongoing relationship

This policy also applies to information that we:

• Collect relating to how you interact with our website
• Must process to complete purchases and other transactions

Consent

Please note that when you submit personal data on our website, you are giving KC Multimedia Ltd your explicit consent that we can use that data in line with our privacy policy.

Opting-out

After giving KC Multimedia Ltd your consent, you are free to amend your consent or withdraw your consent at any time. You have the right to object to the processing of your data. To opt-out, change your preferences or revoke your consent, simply contact us by emailing dataprocessor@kcmultimedia.ltd.

Data processing and storage

KC Multimedia Ltd collects and stores data in the UK. We will store your data for a period of 18 months after your last recorded login attempt unless otherwise noted and explicitly stated.

KC Multimedia Ltd stores data relating to transactions, payments and orders for a period of up to seven years. This period may be extended under certain circumstances as part of our ongoing commitment to comply with UK and international law.

We use carefully selected and recognised third-parties to help us take payments, provide commerce services and manage company accounts. Some of these third-parties may operate outside the European Union.

KC Multimedia Ltd may process your data based on more than one legal ground.

Circumstances under which we may be required to process your data under more than one legal ground may include:

Marketing and communications

KC Multimedia Ltd may send you marketing communications if you have given us your contact details and opted-in to marketing communications.

You can opt-out of these marketing communications and manage your preferences at any time.

Our company obligations

As a data controller, KC Multimedia Ltd is legally responsible for the data you provide us with. In honouring that responsibility, we pledge to uphold our commitments under GDPR and the Data Protection Act 2018.

We will only ever use your data:

• In ways that are both fair and legal
• As described within this policy
• In ways that are necessary for the purposes described

In addition, KC Multimedia Ltd processes the personal data you submit to us or we collect as a data processor. As part of this role, KC Multimedia Ltd takes all necessary precautions to secure the personal data we collect, process and store.

We may occasionally use the data you provide us with for marketing, relationship management or account management activities. These activities are designed to ensure you have adequate information about other products and/or services we offer, that we have reason to believe you may be interested in. You have the right to opt-out of these activities at any time.

Third-Parties

KC Multimedia Ltd never shares your personal data with third-parties unless those parties have been explicitly mentioned within our privacy statement.

Our security

As part of our ongoing commitment to GDPR, KC Multimedia Ltd will report any security breaches or attempted breaches to the relevant authorities within 24 hours. We will subsequently contact all those affected by the breach within 72 hours of its occurrence.

Legitimate interests

As part of the Data Protection Act 2018, KC Multimedia Ltd observes the right to share selected information with third-parties that use data for non-marketing purposes. This could include (but is not limited to) organisations that provide credit assessments, identification services and fraud prevention activities.

Contact us

KC Multimedia Ltd is committed to upholding your rights. If you have any questions, comments or concerns about this privacy policy or wish to exercise your rights in relation to your personal data, please contact Ken Cope at KC Multimedia Ltd.

We will process any request within 30 days. Subject Access Requests are normally performed free of charge, but we may need to charge individuals for excessive or unreasonable data requests.

Complaints

If you are not happy with how your personal data has been processed, you should contact Ken Cope in the first instance by using the contact details listed above. If Ken Cope is unable to satisfy your concerns, you have the right to apply to the Information Commissioner’s Office for a resolution.

You can contact the Information Commissioner’s Office at the following address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

www.ico.org.uk

Here at KC Multimedia Ltd, we take privacy seriously. That is why we take every possible precaution to protect personal data, and actively work to avoid any data protection breaches which could compromise our data security, or the personal rights of our clients, customers, stakeholders or anyone else associated with our company.

To mitigate the risk that any such data compromise could pose, we have developed the following data breach policy. It is an integral part of our compliance responsibilities under the General Data Protection Regulation and Data Protection Act 2018, and is designed to develop clear lines of responsibility and processes that must be followed to adequately mitigate and manage data breach and security incidents.

What does this policy cover?

The scope of this data breach policy encompasses all personal and sensitive data our company holds. This data breach policy applies to everyone at our company – including employees, temporary or casual staff, consultants, suppliers, contractors, freelance workers or other data processors who are storing or processing data on the behalf of our company.

What is the purpose of this policy?

The purpose of this data breach policy is to contain all data breaches and to minimise the risks associated with any breaches. It also outlines the actions that should be taken in the event of a breach to ensure data is secure and to prevent further breaches.

About data breaches

A data breach is defined as any incident, event or action that has the potential to compromise the availability of data, the integrity of data, confidentiality or our company’s data systems. This includes incidents or events that happen by accident or deliberately. Both confirmed and suspected incidents may qualify as a data breach.

For the purposes of this data breach policy, an incident may include (but is not limited to) any of the following:

• Unauthorised use or accessing of data
• Unauthorised modification of data
• Loss of personal or sensitive data
• Theft of personal or sensitive data
• Loss or theft of equipment on which data has been stored
• Individual error
• Any attempts to gain access to data or our company IT systems (both successful or failed)
• Defacement of web property
• Physical incidents, like a fire, which could compromise IT systems

How to report a data breach

All employees who access, manage or use data in any way are responsible for reporting a data breach or any other type of security incident. This report should be made immediately to the employee’s line manager, using the data breach reporting form.

This report must include full details of the incident or breach, when it occurred, who the data relates to and how. It must also include details about the individual reporting the incident.

If a data breach or a data security incident occurs outside of normal company hours, or a data breach or data security incident is discovered outside of normal company hours, it must be reported as soon as possible.

Any violation of this data breach policy could result in disciplinary action procedures taking place for company employees.

Data breach containment and data recovery

All necessary steps must be immediately carried out to minimise the effects of any data security breach or data security incident. This process of containment should begin with an initial assessment designed to establish the severity of the incident. The initial assessment should also include analysing whether there is any way to recover the lost data, and mitigate further risks associated with the incident.

Your initial assessment should include the following information:

• The data involved
• Whether the data involved is sensitive in nature
• The individuals affected
• The security measures that are in place to protect the data
• What has happened to the data
• Whether the data involved could be used in an illegal or otherwise inappropriate way
• Any perceived wider consequences associated with the breach or incident

Data breach notification

KC Multimedia Ltd will determine which individuals must be notified in the event of a data breach or data security incident. Each incident must be assessed on a case-by-case basis. In every instance, the following considerations will be made:

• Any contractual notification requirements
• Any legal notification requirements
• How many people are affected
• What consequences may occur as a result of the data breach or data security incident
• Whether notification of a breach or incident would help the individual to mitigate risks associated with the incident
• Whether notification could assist the company in meeting its legal obligations under GDPR and Data Protection Act 2018
• Whether notifying an individual could prevent the unauthorised or illegal use of data
• Whether KC Multimedia Ltd must notify the Information Commissioner’s Office

All data breaches and data security incidents, both suspected and verified, must be recorded, to assist in further analysis and to help prevent further breaches.

The danger of notifying too many individuals

There will be data security incidents in which a large number of individuals will need to be notified. However, there will be other incidents in which notifying a large number of individuals may have the potential to cause disproportionate enquiries.

Whenever we notify an individual whose personal data has been affected by an incident or breach, that notification must include a description of when the breach occurred, how the breach occurred and what data was involved. Notifications must also include explicit guidance concerning what said individual can do to protect themselves. We should also outline to concerned individuals what steps our company has already taken to mitigate risks.

Data breach evaluation and response

After the data breach or data security incident has been contained by carrying out all necessary measures, KC Multimedia Ltd will conduct an extensive review detailing:

• The cause(s) of the breach
• The effectiveness of any responses
• Whether changes to existing IT systems, company procedures or policies must be implemented

All existing protocols must be reviewed to analyse their adequacy. Any necessary amendments to protocols must be identified and carried out as soon as possible.