In its everyday business operations Online Integrated Solutions (OIS) makes use of a variety of data about identifiable individuals, including data about:

• Current, past and prospective employees
• Customers
• Users of its websites
• Subscribers
• Other stakeholders

In collecting and using this data, the organisation is subject to a variety of legislation controlling how such activities may be carried out and the safeguards that must be put in place to protect it.

The purpose of this policy is to set out the relevant legislation and to describe the steps OIS is taking to ensure that it complies with it.

This control applies to all systems, people and processes that constitute the organisation's information systems, including board members, directors, employees, suppliers and other third parties who have access to OIS systems.

The following policies and procedures are relevant to this document:

• Data Protection Impact Assessment Process
• Personal Data Analysis Procedure
• Legitimate Interest Assessment Procedure
• Information Security Incident Response Procedure
• GDPR Roles and Responsibilities
• Other stakeholders

Where appropriate to the classification of information and the storage medium, cryptographic techniques were used to ensure the confidentiality and integrity of records.

Absolute care have been taken to ensure that encryption keys used to encrypt records are securely stored for the life of the relevant records and comply with the organisation's policy on cryptography.

The General Data Protection Regulation 2016 (GDPR) is one of the most significant pieces of legislation affecting the way that OIS carries out its information processing activities. Significant fines are applicable if a breach is deemed to have occurred under the GDPR, which is designed to protect the personal data of citizens of the European Union. It is OIS's policy to ensure that our compliance with the GDPR and other relevant legislation is clear and demonstrable at all times.

There are a total of 26 definitions listed within the GDPR and it is not appropriate to reproduce them all here. However, the most fundamental definitions with respect to this policy are as follows:

Personal data is defined as:

any information relating to an identified or identifiable natural person ('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;

'processing' means

any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

'controller' means

the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

There are a number of fundamental principles upon which the GDPR is based.
These are as follows:

1. Personal data shall be:

(a) processed lawfully, fairly and in a transparent manner in relation to the data subject ('lawfulness, fairness and transparency');

(b) 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, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes ('purpose limitation');

(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ('data minimisation');

(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay ('accuracy');

(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are 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 in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject ('storage limitation');

(f) 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 ('integrity and confidentiality').

(f) 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 ('integrity and confidentiality').

OIS will ensure that it complies with all of these principles both in the processing it currently carries out and as part of the introduction of new methods of processing such as new IT systems.

The data subject also has rights under the GDPR. These consist of:

The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling

Each of these rights are supported by appropriate procedures within OIS that allow the required action to be taken within the timescales stated in the GDPR.

These timescales are shown in Table 1.

Data Subject Request	Timescale
The right to be informed	When data is collected (if supplied by data subject) or within one month (if not supplied by data subject)
The right of access	One month
The right to rectification	One month
The right to erasure	Without undue delay
The right to restrict processing	Without undue delay
The right to data portability	One month
The right to object	On receipt of objection

Table 1 - Timescales for data subject requests

There are six alternative ways in which the lawfulness of a specific case of processing of personal data may be established under the GDPR. It is OIS policy to identify the appropriate basis for processing and to document it, in accordance with the Regulation. The options are described in brief in the following sections.

Unless it is necessary for a reason allowable in the GDPR, OIS will always obtain explicit consent from a data subject to collect and process their data. In case of children below the age of 16 (a lower age may be allowable in specific EU member states) parental consent will be obtained. Transparent information about our usage of their personal data will be provided to data subjects at the time that consent is obtained and their rights with regard to their data explained, such as the right to withdraw consent. This information will be provided in an accessible form, written in clear language and free of charge. If the personal data are not obtained directly from the data subject then this information will be provided to the data subject within a reasonable period after the data are obtained and definitely within one month.

Where the personal data collected and processed are required to fulfil a contract with the data subject, explicit consent is not required. This will often be the case where the contract cannot be completed without the personal data in question e.g. a delivery cannot be made without an address to deliver to.

If the personal data is required to be collected and processed in order to comply with the law, then explicit consent is not required. This may be the case for some data related to employment and taxation for example, and for many areas addressed by the public sector.

In a case where the personal data are required to protect the vital interests of the data subject or of another natural person, then this may be used as the lawful basis of the processing. OIS will retain reasonable, documented evidence that this is the case, whenever this reason is used as the lawful basis of the processing of personal data. As an example, this may be used in aspects of social care, particularly in the public sector.

Where OIS needs to perform a task that it believes is in the public interest or as part of an official duty then the data subject's consent will not be requested. The assessment of the public interest or official duty will be documented and made available as evidence where required.

If the processing of specific personal data is in the legitimate interests of OIS and is judged not to affect the rights and freedoms of the data subject in a significant way, then this may be defined as the lawful reason for the processing. Again, the reasoning behind this view will be documented.

OIS has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect or process personal data will be subject to due consideration of privacy issues, including the completion of one or more data protection impact assessments.

The data protection impact assessment will include:

Consideration of how personal data will be processed and for what purposes
Assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s)

Assessment of the risks to individuals in processing the personal data
What controls are necessary to address the identified risks and demonstrate compliance with legislation
Use of techniques such as data minimization and pseudonymisation will be considered where applicable and appropriate.

OIS will ensure that all relationships it enters into that involve the processing of personal data are subject to a documented contract that includes the specific information and terms required by the GDPR. For more information, see the GDPR Controller-Processor Agreement Policy

Transfers of personal data outside the European Union will be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the GDPR. This depends partly on the European Commission's judgement as to the adequacy of the safeguards for personal data applicable in the receiving country and this may change over time.
Intra-group international data transfers will be subject to legally binding agreements referred to as Binding Corporate Rules (BCR) which provide enforceable rights for data subjects.

A defined role of Data Protection Officer (DPO) is required under the GDPR if an organisation is a public authority, if it performs large scale monitoring or if it processes particularly sensitive types of data on a large scale. The DPO is required to have an appropriate level of knowledge and can either be an in-house resource or outsourced to an appropriate service provider.

Based on these criteria, OIS appointed Data Protection Officer, below are the contact details:

Name: Archibald Coker
Email: acoker@oisservices.com
Contact: +44 (0) 207 832 0001

It is OIS's policy to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. In line with the GDPR, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours. This will be managed in accordance with our Information Security Incident Response Procedure which sets out the overall process of handling information security incidents.

Under the GDPR the relevant DPA has the authority to impose a range of fines of up to four percent of annual worldwide turnover or twenty million Euros, whichever is the higher, for infringements of the regulations.

The following actions are undertaken to ensure that OIS complies at all times with the accountability principle of the GDPR:

• The legal basis for processing personal data is clear and unambiguous
• A Data Protection Officer is appointed with specific responsibility for data protection in the organisation (if required)
• All staff involved in handling personal data understand their responsibilities for following good data protection practice
• Training in data protection has been provided to all staff
• Rules regarding consent are followed
• Routes are available to data subjects wishing to exercise their rights regarding personal data and such enquiries are handled effectively
• Regular reviews of procedures involving personal data are carried out
• Privacy by design is adopted for all new or changed systems and processes

The following documentation of processing activities is recorded:

• Organisation name and relevant details
• Purposes of the personal data processing
• Categories of individuals and personal data processed
• Categories of personal data recipients
• Agreements and mechanisms for transfers of personal data to non-EU countries including details of controls in place
• Personal data retention schedules
• Relevant technical and organisational controls in place

These actions are reviewed on a regular basis as part of the management process concerned with data protection.

There are 8 data protection principles which ensure that organisations collect, store and process personal data in a way that protects the confidentiality of customers. These principles are set out in schedule 1 of the Act and are as follows:

i. Data must be handled fairly and lawfully
We have legitimate grounds to obtain, store and process customers' data, namely, to assist you obtain a passport, visa and for other purposes authorised by the law and contracts between us and our customers. We ensure that your data will not be used for anything unlawful.

ii. Personal data shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
Due to the nature of our job, the purpose for which you are giving us your personal data is obvious to you and us. We will not use your data for any other purpose incompatible with the original purpose unless you first give us your consent or we are compelled by law to do so.

iii. Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
We will only take information we consider relevant and sufficient to deliver our contract with you.

iv. Personal data shall be accurate and, where necessary, kept up to date.
We ensure that the personal data you give us is correct and not misleading. We achieve this by giving you the opportunity to confirm the information you give us and also by requesting documentary proof when necessary. If there are relevant changes in your personal data, eg, change of name or nationality, please let us know as soon as possible so that we can update your record.

v. Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will, from time to time, review our data base to see if some personal data are still needed to be stored by us. If the purpose for which they were stored has been achieved and we consider that it is no longer necessary to continue storing them, we will securely delete them.

vi. Personal data shall be processed in accordance with the rights of data subjects under this Act.
We will process your personal data in such a way that it will enable you to do any of the following:

• a right of access to a copy of your personal data, popularly known as 'subject access request'. The current fee for that is £10 per standard request and we aim to provide this within 14 days. Subject Access Request should be made to info@oisservices.com by email or by post The Head of Centre, OIS Services, 56-57 Fleet street, EC4Y 1JU, London
• a right to object to processing your personal data in a way that is likely to cause damage or distress to you;
• a right to prevent processing your personal data in a way that is incompatible to the original purpose or purposes;
• a right to object to decisions being taken by automated means;
• a right, when appropriate, to have inaccurate personal data rectified, blocked or deleted, and
• a right to claim compensation for damages caused by a breach of the Act.

vii. Personal data security
Your personal data are held in a very secure environment both physically and technically. The areas where personal data are kept are out of bounds for all non-authorised persons. Access to these parts of the premises can only be gained by electronic key issued only to authorised persons. Your personal data can only be accessed on the system by authorised persons. Only such authorised persons can alter, disclose or destroy your personal data. Further, such authorised persons can only carry out any of those functions in the course of their lawful duties. Therefore, the chances of your personal data being unlawfully processed or accidentally damaged, destroyed or lost are very minimal. Further, it is our policy to ensure that:

• each authorised employee who has access to personal data has his own password which is not shared with other persons,
• approved security software and firewall are used to protect our data,
• printed personal data not in use are shredded,
• we discourage personal data being stored on laptops and other mobile devices and media but if they do, should be locked securely and not taken out of the office.

viii. Transfer of personal data outside the European Economic Area
Your personal data will not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data. There are only few counties outside the EEA that have been accepted as having adequate levels of protection for the processing of persona data comparable to the EEA countries. When we are transferring personal data to the USA, we ensure that the recipient is a signatory to the US Department of Commerce Safe Harbour Scheme. This scheme is recognised by the European Commission as providing adequate protection for data subjects. In relation to other countries outside the EEA that have not been accepted as having equivalent security and safeguards in place for processing personal data, we either sign a separate contract, the terms of which are approved by the European Directives or ensure that there is a clause in the contract that protects the processing of personal data of all our clients.