Data Security Policy
This Data Protection Policy sets out how Environment Conservation ("the Company")
DBA Meta Index handles the personal data of our customers, suppliers, employees,
workers and other third parties ("Data Subjects"). We are the data controller of all
personal data relating to Data Subjects and the personal data used in our business for
our own commercial purposes.
This policy applies to all personal data (any information identifying a Data
Subject or information relating to a Data Subject that we can identify (directly or
indirectly) from that data alone or in combination with other identifiers we
possess or can reasonably access) the Company Processes regardless of the
media on which that data is stored or whether it relates to past or present
employees, workers, customers, clients or supplier contacts, shareholders,
website users, or any other Data Subject.
- 1.2. This policy applies to all employees, workers, contractors, agency workers,
consultants, directors, members, and others.
You must read, understand and comply with this policy when processing
personal data on the Company's behalf and attend training on its requirements.
This policy sets out what we expect from you in order for the Company to comply
with applicable law. Your compliance with this policy is mandatory. Any breach of
this policy may result in disciplinary action.
- 1.4. This policy is an internal document and cannot be shared with third parties,
clients or regulators without prior authorisation from the Compliance Manager.
- 1.5. This policy does not form part of any contract of employment or contract for
services and we may amend it at any time without notice.
- 1.6. This Policy does not override any applicable national data privacy laws and
regulations in countries where the Company operates.
We recognise that the correct and lawful treatment of personal data will
maintain confidence in the organisation and will provide for successful business
operations. Protecting the confidentiality and integrity of personal data is a critical
responsibility that we take seriously at all times. The Company is exposed to
potential fines for failure to comply with the provisions prevalent regulation such
as GDPR and other national equivalents.● 2.2. All levels of management are responsible for ensuring you comply with this
Policy and need to implement appropriate practices, processes, controls and
training to ensure such compliance.
- 2.3. Please contact the Compliance Manager with any questions about the
operation of this policy or the prevailing Data Protection Regulation or other data
protection laws or if you have any concerns that this Policy is not being or has
not been followed. In particular, you must always contact the Compliance
Manager in the following circumstances:
2.3.1. if you are unsure of the lawful basis which you are relying on to
process personal data (including the legitimate interests used by the
Company) (see section 5.1 below);
○ 2.3.2. if you need to rely on consent and/or need to capture explicit
○ 2.3.3. if you need to draft privacy notices (see section 5.3 below);
○ 2.3.4. if there has been a personal data Breach (section 10.2 below);
○ 2.3.5. if you need any assistance dealing with any rights invoked by a
Data Subject (see section 12);
○ 2.3.6. whenever you are engaging in a significant new, or change in,
processing activity which is likely to require a Data Protection Impact
Assessment ("DPIA") (see section 13.4 below) or plan to use personal
data for purposes others than what it was collected for;
○ 2.3.7. you need help complying with applicable law when carrying out
direct marketing activities (see section 13.6 below); or
- PERSONAL DATA PROTECTION PRINCIPLES
- 1. We have elected and adhere to the principles relating to processing of
personal data set out in the GDPR, which are set out within sections 5 to 13 of
this policy. We are responsible for and must be able to demonstrate compliance
with these principles.
- LAWFULNESS, FAIRNESS, TRANSPARENCY
○ 2.1. Lawfulness and fairness
■ 2.1.1. Personal data must be Processed lawfully, fairly and in a
transparent manner in relation to the Data Subject.
■ 2.1.2. You may only collect, process and share personal data fairly
and lawfully and for specified purposes. The GDPR restricts ouractions regarding personal data to specified lawful purposes. These
restrictions are not intended to prevent processing but ensure that
we process personal data fairly and without adversely affecting the
■ 2.1.3. The GDPR allows processing for specific purposes, some of
which are set out below:
■ (a) the Data Subject has given his or her consent;
■ (b) the processing is necessary for the performance of a
contract with the Data Subject;
■ (c) to meet our legal compliance obligations.;
■ (d) to protect the Data Subject's vital interests;
■ (e) to pursue our legitimate interests for purposes where
they are not overridden because the processing prejudices
the interests or fundamental rights and freedoms of Data
Subjects. The purposes for which we process personal data
for legitimate interests need to be set out in applicable
■ 5.1.4 You must identify and document the legal ground being relied
on for each processing activity.
○ 2.2. Consent
■ 2.2.1. A Data Controller must only process personal data on the
basis of one or more of the lawful bases set out in the GDPR, which
■ 2.2.2. A Data Subject consents to processing of their personal data
if they indicate agreement clearly either by a statement or positive
action to the processing. Consent requires affirmative action so
silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If
consent is given in a document which deals with other matters, then
the consent must be kept separate from those other matters.
■ 2.2.3. Data Subjects must be easily able to withdraw consent to
processing at any time and withdrawal must be promptly honoured.
Consent may need to be refreshed if you intend to process
personal data for a different and incompatible purpose which was
not disclosed when the Data Subject first consented.
■ 2.2.4. Unless we can rely on another legal basis of processing,
explicit consent is usually required for processing sensitive
personal data, for automated decision-making and for cross border
data transfers. Usually we will be relying on another legal basis(and not require explicit consent) to process most types of sensitive
data. Where explicit consent (in writing) is required, you must issue
a consent notice to the Data Subject to capture explicit consent.
You will need to evidence consent captured and keep
records of all consents so that the Company can demonstrate
compliance with consent requirements.
○ 2.3. Transparency (notifying data subjects)
■ 2.3.1. The GDPR requires data controllers to provide detailed,
specific information to Data Subjects depending on whether the
information was collected directly from Data Subjects or from
elsewhere. Such information must be provided through appropriate
privacy notices which must be concise, transparent, intelligible,
easily accessible, and in clear and plain language so that a Data
Subject can easily understand them.
Whenever we collect personal data directly from Data
Subjects, including for human resources or employment purposes,
we must provide the Data Subject with all the information required
by the GDPR including the identity of the data controller, how and
why we will use, process, disclose, protect and retain that personal
data through a privacy notice which must be presented when the
Data Subject first provides the personal data
■ 2.3.3. When personal data is collected indirectly (for example, from
a third party or publicly available source), you must provide the
Data Subject with all the information required by the GDPR as soon
as possible after collecting/ receiving the data. You must also check
that the personal data was collected by the third party in
accordance with the GDPR and on a basis which contemplates our
proposed processing of that personal data.
- PURPOSE LIMITATION
Personal data must be collected only for specified, explicit and legitimate
purposes. It must not be further processed in any manner incompatible with
- 3.2. You cannot use personal data for new, different or incompatible purposes
from that disclosed when it was first obtained unless you have informed the Data
Subject of the new purposes and they have consented where necessary.
- DATA MINIMISATION● 4.1. Personal data must be adequate, relevant and limited to what is necessary
in relation to the purposes for which it is processed.
- 4.2. You may only process personal data when performing your job duties
requires it. You cannot process personal data for any reason unrelated to your
- 4.3. You may only collect personal data that you require for your job duties: do
not collect excessive data. Ensure any personal data collected is adequate and
relevant for the intended purposes.
- 4.4. You must ensure that when personal data is no longer needed for specified
purposes, it is deleted or anonymized in accordance with the Company's data
- 5.1. Personal data must be accurate and, where necessary, kept up to date. It
must be corrected or deleted without delay when inaccurate.
- 5.2. You will ensure that the personal data we use and hold is accurate,
complete, kept up to date and relevant to the purpose for which we collected it.
You must check the accuracy of any personal data at the point of collection and
at regular intervals afterwards. You must take all reasonable steps to destroy or
amend inaccurate or out of-date personal data.
- STORAGE LIMITATION
- 6.1. Personal data must not be kept in an identifiable form for longer than is
necessary for the purposes for which the data is processed.
- 6.2. You must not keep personal data in a form which permits the identification of
the Data Subject for longer than needed for the legitimate business purpose or
purposes for which we originally collected it including for the purpose of satisfying
any legal, accounting or reporting requirements.
- 6.3. The Company will maintain retention policies and procedures to ensure
personal data is deleted after a reasonable time for the purposes for which it was
being held, unless a law requires such data to be kept for a minimum time.
- 6.4. You will take all reasonable steps to destroy or erase from our systems all
personal data that we no longer require in accordance with all the Company's
applicable records retention schedules and policies. This includes requiring third
parties to delete such data where applicable.
- 6.5. You will ensure Data Subjects are informed of the period for which data is
stored and how that period is determined in any applicable privacy notice.
- SECURITY INTEGRITY AND CONFIDENTIALITY● 7.1. Protecting personal data
Personal data must be secured by appropriate technical and
organisational measures against unauthorised or unlawful processing, and
against accidental loss, destruction or damage.
○ 7.1.2. We will develop, implement and maintain safeguards appropriate to
our size, scope and business, our available resources, the amount of
personal data that we own or maintain on behalf of others and identified
risks (including use of encryption and pseudonymisation where
applicable). We will regularly evaluate and test the effectiveness of those
safeguards to ensure security of our processing of personal data. You are
responsible for protecting the personal data we hold. You must implement
reasonable and appropriate security measures against unlawful or
unauthorised processing of personal data and against the accidental loss
of, or damage to, personal data. You must exercise particular care in
protecting sensitive personal data from loss and un authorised access,
use or disclosure.
○ 7.1.3. You must follow all procedures and technologies we put in place to
maintain the security of all personal data from the point of collection to the
point of destruction. You may only transfer personal data to third-party
service providers who agree to comply with the required policies and
procedures and who agree to put adequate measures in place, as
○ 7.1.4. You must maintain data security by protecting the confidentiality,
integrity and availability of the personal data, defined as follows:
(a) Confidentiality means that only people who have a need to
know and are authorised to use the personal data can access it.
■ (b) Integrity means that personal data is accurate and suitable for
the purpose for which it is processed.
■ (c) Availability means that authorised users are able to access the
personal data when they need it for authorised purposes.
You must comply with and not attempt to circumvent the
administrative, physical and technical safeguards we implement and
maintain in accordance with the GDPR and relevant standards to protect
- 7.2. Reporting a personal data breach
7.2.1. The GDPR requires data controllers to notify any personal databreach to the applicable regulator and, in certain instances, the Data
A "personal data breach" means any act or omission that
compromises the security, confidentiality, integrity or availability of
personal data or the physical, technical, administrative or organisational
safeguards that we or our third-party service providers put in place to
protect it. The loss, or unauthorised access, disclosure or acquisition, of
personal data is a personal data breach.
○ 7.2.3. We have put in place procedures to deal with any suspected
personal data breach and will notify Data Subjects or any applicable
regulator where we are legally required to do so.
○ 7.2.4. If you know or suspect that a personal data breach has occurred,
do not attempt to investigate the matter yourself. Immediately contact the
Compliance Manager for personal data breaches. You should preserve all
evidence relating to the potential personal data breach.
- DATA SUBJECT'S RIGHTS AND REQUESTS
- 8.1. Data Subjects have rights when it comes to how we handle their personal
data. These include rights to:
8.1.1. withdraw consent to processing at any time;
○ 8.1.2. receive certain information about the Data Controller's processing
○ 8.1.3. request access to their personal data that we hold;
prevent our use of their personal data for direct marketing
○ 8.1.5. ask us to erase personal data if it is no longer necessary in relation
to the purposes for which it was collected or processed or to rectify
inaccurate data or to complete incomplete data;
○ 8.1.6. restrict processing in specific circumstances;
○ 8.1.7. challenge processing which has been justified on the basis of our
legitimate interests or in the public interest;
object to decisions based solely on automated processing,
○ 8.1.9. prevent processing that is likely to cause damage or distress to the
Data Subject or anyone else;
○ 8.1.10. be notified of a personal data breach which is likely to result in high
risk to their rights and freedoms;
○ 8.1.11. make a complaint to the supervisory authority; and○ 8.1.12. in limited circumstances, receive or ask for their personal data to
be transferred to a third party in a structured, commonly used and
machine readable format.
- 8.2. You must verify the identity of an individual requesting data under any of the
rights listed above (do not allow third parties to persuade you into disclosing
personal data without proper authorisation).
- 8.3. You must immediately forward any Data Subject request you receive to
- 9.1. The data controller must implement appropriate technical and organisational
measures in an effective manner, to ensure compliance with data protection
principles. The data controller is responsible for, and must be able to
demonstrate, compliance with the data protection principles.
9.1.1. The Company must have adequate resources and controls in place
to ensure and to document GDPR compliance including:
■ (a) appointing an executive accountable for data privacy;
■ (b) implementing privacy by design when processing personal data
and completing data protection impact assessments (DPIAs) where
processing presents a high risk to rights and freedoms of Data
■ (c) integrating data protection into internal documents including this
Policy, any related documents or privacy notices;
■ (d) regularly training you on the GDPR, internal policies and
procedures, and data protection matters including, for example,
Data Subject's rights, consent, legal basis, DPIA and personal data
breaches. The Company must maintain a record of training
attendance by everyone it employs and engages; and
■ (e) regularly testing the privacy measures implemented and
conducting periodic reviews and audits to assess compliance,
including using results of testing to demonstrate compliance
- 9.2. Record keeping
9.2.1. The GDPR requires us to keep full and accurate records of all our
data processing activities.○ 9.2.2. You must keep and maintain accurate corporate records reflecting
our processing including records of Data Subjects' consents and
procedures for obtaining consents.
○ 9.2.3. These records should include, at a minimum, the name and contact
details of the data controller, clear descriptions of the personal data types,
Data Subject types, processing activities, processing purposes, third-party
recipients of the personal data, personal data storage locations, personal
data transfers, the personal data's retention period and a description of the
security measures in place. In order to create such records, data maps
should be created which should include the detail set out above together
with appropriate data flows.
- 9.3. Training and audit
9.3.1. We are required to ensure you have undergone adequate training
to enable them to comply with data privacy laws. We must also regularly
test our systems and processes to assess compliance.
○ 9.3.2. You must undergo all mandatory data privacy related training and
ensure your team undergo similar mandatory training.
○ 9.3.3. You must regularly review all the systems and processes under
your control to ensure they comply with this Policy and check that
adequate governance controls and resources are in place to ensure
proper use and protection of personal data.
- 9.4. Privacy by design and DPIAs
We are required to implement privacy by design measures when
processing personal data by implementing appropriate technical and
organisational measures (like pseudonymisation) in an effective manner,
to ensure compliance with data privacy principles.
You must assess what privacy by design measures can be
implemented on all programs/systems/processes that process personal
data by taking into account the following:
■ (a) the state of the art;
■ (b) the cost of implementation;
■ (c) the nature, scope, context and purposes of processing; and
■ (d) the risks of varying likelihood and severity for rights and
freedoms of Data Subjects posed by the processing
○ 9.4.3. Data controllers must also conduct DPIAs in respect to high risk
You should conduct a DPIA (and discuss your findings with the
Compliance Manager) when implementing major system or business
change programs involving the processing of personal data including:
■ (a) use of new technologies (programs, systems or processes), or
changing technologies (programs, systems or processes);
■ (b) Automated processing including profiling and auto-mated
■ c) large scale processing of sensitive data; and
■ (d) large scale, systematic monitoring of a publicly accessible area.
○ 9.4.5. A DPIA must include
(a) a description of the processing, its purposes and the data
controller's legitimate interests if appropriate;
■ (b) an assessment of the necessity and proportionality of the
processing in relation to its purpose;
■ (c) an assessment of the risk to individuals; and
■ (d) the risk mitigation measures in place and demonstration of
- 9.5. Automated processing (including profiling) and automated decision-making
9.5.1. Generally, ADM is prohibited when a decision has a legal or similar
significant effect on an individual unless:
○ 9.5.2. If certain types of sensitive data are being processed, then grounds
(b) or (c) will not be allowed but such sensitive data can be processed
where it is necessary (unless less intrusive means can be used) for
substantial public interest like fraud prevention.
■(a) a Data Subject has explicitly consented;
■ (b) the processing is authorised by law; or
■ (c) the processing is necessary for the performance of or entering
into a contract.
If a decision is to be based solely on automated processing
(including profiling), then Data Subjects must be informed when you first
communicate with them of their right to object. This right must be explicitly
brought to their attention and presented clearly and separately from other
information. Further, suitable measures must be put in place to safeguard
the Data Subject's rights and freedoms and legitimate interests.○ 9.5.4. We must also inform the Data Subject of the logic involved in the
decision making or profiling, the significance and envisaged
consequences and give the Data Subject the right to request human
intervention, express their point of view or challenge the decision.
A DPIA must be carried out before any automated processing
(including profiling) or ADM activities are undertaken.
- 9.6. Direct marketing
9.6.1. We are subject to certain rules and privacy laws when marketing to
For example, a Data Subject's prior consent is required for
electronic direct marketing (for example, by email, text or automated
calls). The limited exception for existing customers known as "soft opt in"
allows organisations to send marketing texts or emails if they have
obtained contact details in the course of a sale to that person, they are
marketing similar products or services, and they gave the person an
opportunity to opt out of marketing when first collecting the details and in
every subsequent message.
○ 9.6.3. The right to object to direct marketing must be explicitly offered to
the Data Subject in an intelligible manner so that it is clearly
distinguishable from other information.
A Data Subject's objection to direct marketing must be promptly
honoured. If a customer opts out at any time, their details should be
suppressed as soon as possible. Suppression involves retaining just
enough information to ensure that marketing preferences are respected in
- 9.7. Sharing personal data
9.7.1. Generally we are not allowed to share personal data with third
parties unless certain safeguards and contractual arrangements have
been put in place.
○ 9.7.2. You may only share the personal data we hold with another
employee, agent or representative of our group (which includes our
subsidiaries and our ultimate holding company along with its subsidiaries)
if the recipient has a job-related need to know the information and the
transfer complies with any applicable cross-border transfer restrictions.
○ 9.7.3. You may only share the personal data we hold with third parties,
such as our service providers if:
(a) they have a need to know the information for the purposes of
providing the contracted services;
■ (b) sharing the personal data complies with the Privacy Notice
provided to the Data Subject and, if required, the Data Subject's
consent has been obtained;
■ (c) the third party has agreed to comply with the required data
security standards, policies and procedures and put adequate
security measures in place;
■ (d) the transfer complies with any applicable cross border transfer
■ (e) a fully executed written contract that contains GDPR approved
third party clauses has been obtained.