Data Policy

Introduction

Acadima needs to gather and use certain information about individuals. These can include customers, suppliers, 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

This data protection policy ensures Acadima:

• 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

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

People, Risks and Responsibilities Policy scope

This policy applies to:

• The head office of Acadima
• All branches of Acadima
• All staff and volunteers of Acadima
• All contractors, suppliers and other people working on behalf of Acadima
• It applies to all data that the company holds relating to identifiable individuals, which can include:
• Names of individuals o Postal addresses
• Email addresses
• Telephone numbers
• Financial payment information
• …plus any other information relating to individuals

Data protection risks

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

• Breaches of confidentiality - information being given out inappropriately
• Failing to offer choice - individuals should be free to choose how the company uses relative data
• Reputational damage - the company could suffer if hackers successfully gained access to data

Responsibilities

Everyone who works for, or with Acadima 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. However, these people have key areas of responsibility:

• The board of directors is responsible for”
• ultimately ensuring that Acadima meets its legal obligations
• The Director of IT, Chris Lojnieski, 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
• Handling data protection questions from staff and anyone else covered by this policy
• Dealing with requests from individuals to see the data Acadima holds about them (also called ‘subject access requests’)
• Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data
• 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 example, cloud computing services
• The Marketing Manager, Ryan Hill, is responsible for:
• Approving any data protection statements attached to communications such as emails letters
• Addressing any data protection queries from journalists or media outlets like newspapers
• Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General Staff guidelines are:

• Staff able to access data covered by this policy are only 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 manager
• Acadima will provide training to all employees to help 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, and they should never be shared
• Personal data should not be disclosed to unauthorised people, 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 manager or the data protection officer 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 or data controller.

• When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it. All sensitive information is kept in a locked room. Furthermore, our offices are equipped with an alarm system & security camera

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

• 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
• Data is stored on servers in Montreal, Quebec, Canada and at our Corporate Headquarters in Costa Mesa, California, United States
• 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 DVD), 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 services o 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.

Data Use

Personal data is of no value to Acadima unless the business can make use of it. However, it is 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. 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
• 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 Acadima 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 Acadima 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 needed. Staff should not create unnecessary data sets
• Staff should take every opportunity to ensure data is updated
• Acadima will make it easy for data subjects to update the information Acadima holds about them
• Data should be updated as inaccuracies are discovered
• 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 Acadima are entitled to:

• Ask what information the company holds about them and how to gain access to it
• Be informed how to keep it up to date and 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 and be addressed to the data controller. The data controller can supply a standard request form (although individuals do not have to use this) and will always verify the identity of anyone making a subject access request before handing over any information.

Providing Information

Acadima 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.

Privacy Policy

Information Collection and Use

Acadima is the sole owner of the information collected. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement.

Order

We request information from the user on our online registration system. Here a user must provide contact information (name, height, ceremony and degree) and financial information (credit card number, expiration date). This information is used for billing purposes and to fill customer's orders. If we have trouble processing an order, this contact information is used to get in touch with the user.

Cookies

A cookie is a piece of information that a Web site transfers to an individual's hard drive for record keeping purposes. Cookies make web surfing easier for you by saving your passwords, purchases, and preferences while you're at our site. The use of cookies is an Industry standard, and you'll find cookies at most websites.

Sharing

We do not share aggregated demographic information.

Security

The importance of security for all personally identifiable information associated with our Guests is of utmost concern. We exercise great care in providing secure transmission of your information from your PC to our servers, utilizing encryption software. Only those employees who need access to your information in order to do their jobs are allowed access, each having signed compressive nondisclosure agreements, which provides explicit legal confidentiality protections. Any employee who violates our privacy and/or security policies is subject to disciplinary action, including possible termination and civil and/or criminal prosecution. If you have any questions about the security at our website, you can send an e-mail to [email protected].

Site and Service Updates

We send the user site and service announcement updates. We communicate with the user to provide requested services and in regards to issues relating to their account via e-mail or phone.

Correction/Updating Personal Information

If a user's personally identifiable information changes (such as your phone number, address and postal code), or if a user no longer desires our service, we will endeavor to provide a way to correct, update or remove that user's personal data provided to us. This can usually be done at the member information page or by e-mailing our Customer Support.