Policy of UIPM

 

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HOW WE USE COOKIES

The European Community recently introduced legislation to protect the privacy of web users


by limiting how websites can use cookies Universal Institute of Professional Management (India) is committed to protecting your

privacy. As part of this commitment we are providing you with information about the cookies we use, so that you can make informed decisions.

 

The information below should be read in conjunction with our Privacy Policy and Terms and Conditions.

 

What are cookies?

 

Cookies are small text files that our website(s) or services provided for us by other companies put on your computer. The information in them helps us to improve your experience of using our website and learning with us. Many of our cookies are deleted when you log out of your learning or close your web browser. None of our cookies contain any of your personally identifiable information.

 

Because you are using our website(s) we assume that you are happy for us to use cookies in this way.

 

If you are not happy, then you should either not use our website(s), set your web browser to


not accept cookies from Universal Institute of Professional Management (India) or use your web browser’s anonymous browsing

setting (this is called ‘Incognito’ in Google Chrome, ‘In Private’ in Internet Explorer and ‘Private Browsing’ in Firefox).

 

For more information on cookies, how to control the use of them in your browser and how to browse the internet anonymously visit the All About Cookies website.

 

Because our learning systems rely on cookies to deliver your courses effectively you give us consent to use cookies as outlined below when you purchase or enroll on a block Universal Institute of Professional Management (India). We will not provide technical support to learners who choose to cookies and then encounter issues with their learning.

 

You will not be able to purchase courses from the Universal Institute of Professional Management (India) website if you set your

browser to not accept cookies as our e-commerce system uses them to process transactions. We are unable to facilitate purchases by any other method (e.g. telephone


sales) or provide technical support to users who choose to block Universal Institute of Professional Management (India) cookies.


 

What cookies Universal Institute of Professional Management (India)uses:

 

Session Cookies

 

We use a number of session cookies to provide functionality including, but not limited to, remembering who you are when you have logged into our website(s) or learning systems, to identify you when you move from one Universal Institute of Professional Management (India)system to another, to greet you by name on screen, to optimize the effectiveness of our web servers and to remember the items you have put into our shopping basket.

 

We consider these cookies to be strictly necessary for the secure and efficient operation of our website(s) and learning systems and make your experience of using them easier and quicker.

 

If these cookies are blocked or disabled then much of the functionality of our systems will be broken.

 

Persistent Cookies

 

We use a number of persistent cookies to provide functionality including, but not limited to, returning you back to the point in your learning you had reached the last time you logged out, to show you content you had looked at on a previous visit to make it easier to find it again, to make sure you are only invited to complete a web survey occasionally and that you don’t see alerts or messages repeatedly during a single webvisit.

 

If these cookies are blocked or disabled then our systems will still be usable, but the user experience will be severely degraded.

 

Double Click (Google)

 

This cookie is used on a small number of pages on the Universal Institute of Professional Management (India)website to track

the effectiveness of our Google Adwords and Google Sponsored Link advertising.

 

For more information on how to permanently opt-out of Double Click placing this cookie on your computer visit http://www.google.com/policies/privacy/ads/#toc-optout or install the Google Advertising Cookie Plugin for your browser http://www.google.com/ads/preferences/plugin/

 

 

Social network cookies

 

Some pages on our website(s) contain social network ‘share’ or ‘like’ buttons. The social network may set a cookie (or cookies) on your PC when you click on one of these buttons.

 

In order to implement these buttons on our website(s) we use code which is hosted by the relevant social network. If you are a member of some of these networks they may use this code to track that you have visited our website(s) whether you click the buttons or not.

 


(Company Name) does not control these cookies or the underlying code. You should

check the privacy statement of the relevant social network before clicking them and/or to find out how they track their members’ behaviour using these elements and how to opt out of this functionality

This policy has been approved & authorised by: Prof. Dr. Mohammad Sameer hasan , President of UIPM India.


Privacy Policy

 

Our commitment to privacy

This privacy statement explains how Universal Institute of Professional Management (India) (referred to as “we”, “us”or “UIPM India”collects information from you via the website or in any manner expressly described in the privacy statement and how this information is then used. When you provide us with your personal data you consent to us processing all such personal data as set out in the privacy statement. Please read this privacy statement carefully and revisit this page from time to time to review any changes that we may have made. If you have any questions, comments or concerns about how we handle your personal information, please ring us on 918709307470 or email us india@uipmcenter.net This statement provides a summary of the full Privacy Policy. Both the statement and the full Privacy Policy apply to information collected by Universal Institute of Professional Management (India) via Prof. Dr. Mohammad Sameer Hasan website and in any manner described in the Privacy Statement.

 

Protecting your personal information

Your personal data is protected by General Data Protection Regulations (GDPR).You can find the details for the UK Information  Commissioner at  https://ico.org.uk/ or by accessing Universal Institute of Professional Management (India) GDPR Statement at Universal Institute of Professional Management (India) As a registered data controller, we are required to take appropriate technical measures to protect your personal information including making a regular backup of our system and data. We have security measures in place to make sure any personal information we collect is secure.Your account is password protected and all information including your password is on a secure server, which only a limited number of employees and sub-contractors can access. All parties with access to your information are subject to confidentiality obligations. If you think someone else knows your password, or is using it, tell us immediately and change your password. You can change your password on the Website.

Even though we take appropriate technical steps to protect your security, you should remember that data transmission over the internet cannot always be guaranteed as 100% secure so you use the website at your own risk.

 

Personal Information

We collect personal data about you when you enroll as a learner. At enrollment, we may ask you for sensitive personal data and for your consent to use it for a specific purpose. If you do not wish to provide this information,you may select the Not Known/Not Provided or Prefer not to say option.

We share some of your personal data with the Awarding Organisation and where relevant with the Skills Funding Agency through their Learner Registration Service.

If government funding is available for your course, we collect personal data from you to see if you can have that funding.

When you access your course materials we collect information about how you use those materials.

You may provide us with further personal data if you use one of our learning or communications facilities or use one of our online skills tests.

We use cookies and other technologies to keep track of how you interact with our website and

to target advertising. For further information about this please see our Use of Cookies Statement.

 

 

Purposes and Disclosures

We use your personal information to deal with your queries, to provide you with the services you request, to determine whether you are eligible for government funding (if available), customer feedback and for general statistics and research.

Depending on the preferences indicated by you:

 

 we may use your personal data to contact you about developments and offers.

Universal Institute of Professional Management (India) may disclose your personal data to your sponsor, if you are being sponsored by your employer or by a trade organisation or other group.  we may disclose your information to certain government agencies in connection with the funding of your course.

 

Following registration and enrollment, either ina Universal Institute of Professional Management (India) Approved Centre or online,

all of our approved service providers will have access to your name, date of birth, address,

username,learner reference number and details of which Universal Institute of Professional Management (India) courses you have

enrolled on in the past. You can request that:

    your details not be used for marketing purposes;

  we provide you with a copy of the information we hold about you (we may charge you a small fee);

  we correct inaccuracies in your information.

 

You may also turn cookies off in your browser. However, if you do so, you may not be able to use certain features on the website.

 

The information we collect during registration or enrollment

When you register with us, you (or the person registering for you) must tell us:

·         your full name

·         email address

·         your date of birth (security question)

·         in which region of the UK you are based

·         where you heard about us.

 

We also ask for your company name but you do not have to provide this information if you do not wish to.

 

Following registration via the Website, we,or our Agents (where you have been introduced to the Website via an Agent or Reseller),may request additional personal data from you in order to further support your learning. You do not have to provide this information,but if you do not, you may not get the most out of your learning.

 

The information we collect when you access Course Materials

We collect information about how you use Course Materials to monitor your learning and improve our users’ learning experience.

 

You may also provide personal data through:

 

·         calls to our helplines;

·         letters and e-mails;

·         customer feedback forms.

 

We may record calls to helplines for quality and training purposes only. We will store calls for about three months and we will keep them confidential. In general, if you contact us, we may keep a record of your query or complaint for a reasonable time in case you contact us again.

 

How we use the information we collect

We use your personal information:

·         to answer your queries or complaints;

·         to deliver our online services, for example any Courses that you have accessto

 

·         to provide Course Materials;

·         to carry out administration;

·         to seek your opinion of the Course and Website

·         for general statistics and research;

·         for obtaining any relevant professional advice;

·         as may be required by law or in connection with legal proceedings (including where we intend to take legal proceedings), or as may be necessary to establish, exercise or defend our legal rights.

 

Paying for a Course online

When you pay for a Course online, you will be asked for:

·         details of a credit or debit card;

·         an e-mail address;and

·         a telephone number.

 

These details are collected by:Paypal :info@uipmcenter.net

They collect credit or debit card details over a secure link. We do not collect them and they are not made available to us or our Agents or Resellers. We will use the personal information youprovidetoprocessyouronlinepaymentandtorefundanymoniesduetoyouifyoucancel your enrollment in line with the terms and conditions on this Website. When you make a payment online, we will use industry standard software, which encrypts your information.For further details about the security of this information, please refer to Paypal :info@uipmcenter.net

 

 

Third parties and sponsors

Toachievethepurposessetoutinthisprivacystatementwemayneedtogiveyourinformation too urser vice providers,Agents and Resellers. Following registration and/or enrollment via the website, we and our Agent or Resellers, if you registered via one of our Agents or Resellers, will have access to your name and contact details to help us deliver our services toyou.

If your employer, trade organisation or other group is sponsoring you, we may give the personal information we have collected to your sponsor to monitor your learning.

 

Requests for information

If you have not registered on the Website but are simply making an enquiry or request for information, we will use your personal information to reply to your enquiry or request. We will not use this information for marketing purposes without your permission or unless you invite us to do so.

 

Keeping your personal data

We keep personal data :

·         for as long as is necessary to fulfil the purposes we collected itfor;

·         as required by law;or

·         to enforce or defend legal claims.

 

Sometimes we will keep information that you have deleted, for example messages sent by you to your tutor, as a record of your learning experience. We will keep this information for a reasonable time.


 

Cookies

We use cookies and other technologies to keep track of how you interact with our website and


to target advertising Please see the Universal Institute of Professional Management (India) Use of Cookies Statement for further information.

 

Your rights

You have the right to:-

·         ask for a copy of all the information we hold about you (we will charge you a small fee for this) and tocorrect any in accuracies.To obtain a copy of this information,please


ring us on 918709307470 or email us at india@uipmcenter.net

·         challenge the accuracy of data held about you.  You can amend your details please


ring us on 918709307470 or email us to request a change

·         take steps to prevent your personal data being processed if the processing is likely to cause you substantial damage or substantial distress which is unjustified. If you want to exercise this right you must put your objection in writing by emailing us,specifying


why the processing has this effect and state what you require to do to avoid causing damage or distress.

 

How to contact us

To obtain a copy of your personal data, to correct inaccuracies or if you have any queries or

concerns about how we handle your personal data,please contact:   Universal Institute of Professional Management (India), 918709307470  &  india@uipmcenter.net

 

This policy has been approved & authorised by: Prof. Dr. Mohammad Sameer Hasan as President of UIPM India.



The Data Protection

Introduction

This Policy sets out the obligations of Universal Institute of Professional Management (India),(“UIPM INDIA”) regarding data protection and the rights of customers and business contacts (“data subjects”) in respect of their personal data under Data Protection Act 2018 (Formally EU Regulation 2016/679 General Data Protection Regulation (“GDPR”)). The Data Protection Act 2018 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.

 

The Data Protection Principles

This Policy aims to ensure compliance with the Data Protection Act 2018. The Data Protection Act 2018 sets out the following principles with which any party handling personal data must comply. All personal data must be:

·         Processed lawfully, fairly, and in a transparent manner in relation to the data subject.

·         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.

·         Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

·         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.

·         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 Data Protection Act 2018 in order to safeguard the rights and freedoms of the data subject.

·         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.

 

The Rights of Data Subjects

·         The Data Protection Act 2018 sets out the following rights applicable to data subjects

·         The right to be informed’

·         The right of access,

·         The right to rectification,

·         The right to erasure (also known as the ‘right to be forgotten’),

·         The right to restrict processing,

·         The right to data portability,

·         The right to object; and

·         Rights with respect to automated decision-making and profiling.

 

Lawful, Fair, and Transparent Data Processing

The Data Protection Act 2018 seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The Data Protection Act 2018 states that processing of personal data shall be lawful if at least one of the following applies:

·         The data subject has given consent to the processing of their personal data for one or more specific purposes;

·         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;

·         The processing is necessary for compliance with a legal obligation to which the data controller is subject;

·         The processing is necessary to protect the vital interests of the data subject or of another natural person;

·         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

·         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.

·         If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s health), at least one of the following conditions must be met:

·         The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);

·         The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;

·         The processing relates to personal data which is clearly made public by the data subject;

·         The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;

 

Specified, Explicit, and Legitimate Purposes

The Company collects and processes the personal data set out in this Policy.

This includes:

·         Personal data collected directly from data subjects OR

·         Personal data obtained from third parties.

·         The Company only collects, processes, and holds personal data for the specific purposes set out in this Policy (or for other purposes expressly permitted by the Data Protection Act 2018).

·         Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data.

·          

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).

 

Accuracy of Data and Keeping Data Up-to-Date

·         The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject.

·         The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

 

Data Retention

·         The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.

·         When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.

·         For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.

 

Secure Processing

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided later in this Policy.

 

Accountability and Record-Keeping

The Company’s Data Protection Officer is Prof. Dr. Mohammad Sameer Hasan

E-Mail: india@uipmcenter.net

Tel: +91 87093 07470

 

The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the Data Protection Act 2018 and other applicable data protection legislation.

·         The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

·         The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;

·         The purposes for which the Company collects, holds, and processes personal data;

·         Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;

·         Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;

·         Details of how long personal data will be retained by the Company; and

·         Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

 

Data Protection Impact Assessments

·         The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data.

·         Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:

1.       The type(s) of personal data that will be collected, held, and processed;

2.       The purpose(s) for which personal data is to be used;

3.       The Company’s objectives;

4.       How personal data is to be used;

5.       The parties (internal and/or external) who are to be consulted;

6.       The necessity and proportionality of the data processing with respect to the

7.       purpose(s) for which it is being processed;

8.       Risks posed to data subjects;

9.       Risks posed both within and to the Company; and

10.   Proposed measures to minimize and handle identified risks.

 

Keeping Data Subjects Informed

The Company shall provide the information set out in section (i) below to every data subject:

Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and 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.

(i)                The following information shall be provided:

 

·         Details of the Company including, but not limited to, the identity of its Data Protection Officer;

·         The purpose(s) for which the personal data is being collected and will be processed (as detailed in this Policy) and the legal basis justifying that collection and processing;

·         Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;

·         Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;

·         Where the personal data is to be transferred to one or more third parties, details of those parties;

·         Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place,

o   Details of data retention;

o   Details of the data subject’s rights under the Data Protection Act 2018;

o   Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;

o   Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the Data Protection Act 2018);

o   Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and

o   Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

 

Data Subject Access

·         Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.

·         Data subjects wishing to make a SAR may do so in writing, using the Company’s Subject Access Request Form, or other written communication. SARs should be addressed to the Company’s Data Protection Officer at Universal Institute of Professional Management (India), India, 201 A Block, Deep Ganga Complex, Ashok Rajpath, Near Arvind Hospital, Patna- 800004, Tel: Tel: +91 87093 07470, Email: india@uipmcenter.net.

·         Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.

·         All SARs received shall be handled by the Company’s Data Protection Officer.

·         The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

Rectification of Personal Data

·         Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.

·         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.

·         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.

 

Erasure of Personal Data

Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

a) It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;

b) The data subject wishes to withdraw their consent to the Company holding and processing their personal data;

c) The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so),

d) The personal data has been processed unlawfully;

e) The personal data needs to be erased in order for the Company to comply with

a particular legal obligation.

Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. 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.

In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

 

Restriction of Personal Data Processing

Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.

In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

 

Objections to Personal Data Processing

Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling) and processing for scientific and/or historical research and statistics purposes.

Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.

Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.

Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Data Protection Act 2018, “demonstrate grounds relating to his or her particular situation”. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.

 

Personal Data Collected, Held, and Processed

The following personal data is collected, held, and processed by the Company:

Microsoft Office,  format Pdf, word, jpg, excel.

 

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:

·         All emails containing personal data must be encrypted using Encryption software;

·         All emails containing personal data must be marked “confidential”;

·         Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;

·         Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;

·         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 using deletion software;

·         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;

·         Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using Royal Mail Registered or 1st or 2nd Class Signed For post; and

·         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”.

 

Data Security – Storage

The Company shall ensure that the following measures are taken with respect to the storage of personal data:

·         All electronic copies of personal data should be stored securely using passwords and data encryption;

·         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;

·         All personal data stored electronically should be backed up at least daily with backups stored onsite. All backups should be encrypted using data encryption’

·         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 without the formal written approval of the Data Protection Officer and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and

·         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 Data Protection Act 2018 (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).

 

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.

 

Data Security – Use of Personal Data

The Company shall ensure that the following measures are taken with respect to the use of

personal data:

·         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 The Data Protection Officer,

·         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 The Data Protection Officer,

·         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;

·         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

·         Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of  Prof. Dr. Mohammad Sameer Hasan 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.

 

Data Security – IT Security

The Company shall ensure that the following measures are taken with respect to IT and information security:

·         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;

·         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;

·         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 after the updates are made available by the publisher or manufacturer, unless there are valid technical reasons not to do so; and

·         No software may be installed on any Company-owned computer or device without the prior approval of the Company.

 

Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

·         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 Data Protection Act 2018 and under this Policy, and shall be provided with a copy of this Policy;

·         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;

·         All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;

·         All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;

·         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;

·         Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;

·         All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;

·         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;

·         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 Data Protection Act 2018 and this Policy by contract;

·         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 Data Protection Act 2018; and

·         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.

 

Transferring Personal Data to a Country Outside the EEA

The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.

The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:

o   The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;

o   The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the Data Protection Act 2018); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;

o   The transfer is made with the informed consent of the relevant data subject(s);

o   The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);

o   The transfer is necessary for important public interest reasons;

o   The transfer is necessary for the conduct of legal claims;

o   The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or

o   The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

 

Data Breach Notification

·         All personal data breaches must be reported immediately to the Company’s Data Protection Officer.

·         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.

·         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.

·         Data breach notifications shall include the following information:

o   The categories and approximate number of data subjects concerned;

o   The categories and approximate number of personal data records concerned;

o   The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);

o   The likely consequences of the breach;

o   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.

 

This policy has been approved & authorised by: Prof. Dr. Mohammad Sameer Hasan, President  of UIPM India