Data Protection Policy
This Policy sets out the obligations of Urban Communications, a company registered in Pakistan Incorporation number C05/PSEB/2018/2833, whose registered office is at Office #5, Floor #3, Adnan Heights, Commercial Market, Chaklala Scheme III, Rawalpindi, Pakistan. (“the Company”) regarding data protection and the rights of customers, business contacts (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).
The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
2. The Data Protection Principles
This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:
2.1 Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
2.2 Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
2.3 Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
2.4 Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.
2.5 Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.
2.6 Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.
3. The Rights Of Data Subjects
The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):
3.1 The right to be informed (Part 12).
3.2 The right of access (Part 13);
3.3 The right to rectification (Part 14);
3.4 The right to erasure (also known as the ‘right to be forgotten’) (Part 15);
3.5 The right to restrict processing (Part 16);
3.6 The right to data portability (Part 17);
3.7 The right to object (Part 18); and
3.8 Rights with respect to automated decision-making and profiling (Parts 19 and 20).
4. Lawful, Fair, And Transparent Data Processing
4.1 The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:
4.1.1 The data subject has given consent to the processing of their personal data for one or more specific purposes;
4.1.2 The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;
4.1.3 The processing is necessary for compliance with a legal obligation to which the data controller is subject;
4.1.4 The processing is necessary to protect the vital interests of the data subject or of another natural person;
4.1.5 The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or
4.1.6 The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6. Adequate, Relevant, And Limited Data Processing
The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 5, above, and as set out in Part 21, below.
7. Secure Processing
All employees log in using passwords and user ID, access to the building is only available through our ID access door entry system.
8. Accountability And Record-Keeping
8.1 The Urban Communications Data Protection Officer can be reached using the following contact details:
Data Protection Officer, Office #5, Floor #3, Adnan Heights, Commercial Market, Chaklala Scheme III, Rawalpindi, Pakistan.
8.2 The Data Protection Officer shall be responsible for overseeing the implementation of this Policy client GPDR Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the GDPR and other applicable data protection legislation.
8.3 The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
8.3.1 The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;
8.3.2 The purposes for which the Company collects and processes personal data using the client dispatch system;
8.3.3 Details of the categories of personal data collected, and processed by the Company, and the categories of data subject to which that personal data relates;
8.3.4 Details of how long personal data will be retained by the Company (please refer to the Company’s Data Retention Policy); and
8.3.5 Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.
9. Data Protection Impact Assessments
9.1 The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal. Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:
9.1.1 The type(s) of personal data that will be collected, and processed;
9.1.2 The purpose(s) for which personal data is to be used;
9.1.3 The Company’s objectives;
9.1.4 How personal data is to be used;
9.1.5 The parties (internal and/or external) who are to be consulted;
9.1.6 The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
9.1.7 Risks posed to data subjects;
9.1.8 Risks posed both within and to the Company; and
9.1.9 Proposed measures to minimise and handle identified risks.
10. Keeping Data Subjects Informed
10.1 The Company shall provide the information set out in Part 12.2 to every data subject:
10.1.1 Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and
10.1.2 Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:
a) if the personal data is used to communicate with the data subject, when the first communication is made; or
b) if the personal data is to be transferred to another party, before that transfer is made; or
c) as soon as reasonably possible and in any event not more than one month after the personal data is obtained.
10.2 The following information shall be provided:
10.2.1 Details of the Company including, but not limited to, the identity of its Data Protection Officer;
10.2.2 The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;
10.2.3 Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
10.2.4 Details of data retention;
10.2.5 Details of the data subject’s rights under the GDPR;
10.2.6 Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
10.2.7 Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the GDPR);
11. Rectification Of Personal Data
11.1 The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
11.2 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.
12. Personal Data Collected, And Processed
The following personal data is collected, and processed by the Company (for details of data retention, please refer to the Company’s Data Retention Policy):
(a) Name, Company name and address, personal phone numbers and email address .
13. Data Security – Transferring Personal Data And Communications
The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:
13.1 All emails containing personal data must be encrypted.
13.2 All emails containing personal data must be marked “confidential”;
13.3 Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
13.4 Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
13.5 Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted.
13.6 Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
13.7 Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient, and
13.8 All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.
14. Data Security – Storage
The Company shall ensure that the following measures are taken with respect to the storage of personal data:
14.1 All electronic copies of personal data should be stored securely using passwords and data encryption;
14.2 All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;
14.3 All personal data stored electronically should be backed up with backups stored onsite and or offsite. All backups should be encrypted;
14.4 No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise; and
14.5 No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).
15. Data Security – Disposal
When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.
16. Data Security – Use Of Personal Data
The Company shall ensure that the following measures are taken with respect to the use of personal data:
16.1 No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from Date Protection Officer;
16.2 No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of Date Protection Officer;
16.3 Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;
16.4 If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and
16.5 Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of Marketing Director to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.
17. Data Security – IT Security
The Company shall ensure that the following measures are taken with respect to IT and information security:
17.1 All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. All software used by the Company is designed to require such passwords.;
17.2 Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
17.3 All software (including, but not limited to, applications and operating systems) shall be kept up- to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates not more than as soon as reasonably and practically possible, unless there are valid technical reasons not to do so; and
17.4 No software may be installed on any Company-owned computer or device without the prior approval of the IT Director.
18. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
18.1 All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy;
18.2 Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
18.3 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
18.4 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
18.5 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
18.6 Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
18.7 All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;
18.8 The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
18.9 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;
18.10 All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the GDPR; and
18.11 Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
19. Data Breach Notification
19.1 All personal data breaches must be reported immediately to the Company’s Data Protection Officer.
19.2 If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
19.3 In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
19.4 Data breach notifications shall include the following information:
19.4.1 The categories and approximate number of data subjects concerned;
19.4.2 The categories and approximate number of personal data records concerned;
19.4.3 The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
19.4.4 The likely consequences of the breach;
19.4.5 Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.
20. Implementation Of Policy
This Policy shall be deemed effective as of 03/12/2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
This Policy has been approved and authorised by:
Name: Major Qalb-i-Abbas
Due for Review by: 03/12/2019