Affino Data Breach Policy

Timing

 

Comrz Ltd trading as Affino will notify the ICO (Information Commissioners Office) within 72 hours of any relevant data security breach.

 

Relevant breaches are those where the individual is likely to suffer some form of damage, such as identity theft or a confidentiality breach.

 

Internal Reporting Policy

 

All Affino staff members and contractors will be made be aware at all times on any instances that may occur that may give rise to a data protection breach.

 

Should a team member become aware of such a breach, this will be notified to the Line Manager, or an alternative manager should the Line Manager not be available, immediately. The Line Manager will in turn notify the nominated Data Protection Office at Affino. This will be done immediately. In addition to notifying the Line Manager a report will be made using the form here.

 

The Data Protection Office will record all breaches within the data Security Incident Report and notify the ICO should the breach be identified as relevant to report.

 

When a personal data breach has occurred, the severity of the resulting risk to the individuals rights and freedoms will be established. If it is likely there will be a risk, then the ICO will be notified immediately, if the risk is unlikely it does not need to be reported. However, if the decision is made not to report the breach to the ICO, this decision will need to be justified, and therefore the reasons documented and attached to the register.

 

Reporting Policy to the ICO

 

IThe breach reporting process is as follows:

• Go to ICO.gov.uk – For Organisation
• Select ‘Report a Breach’
• Within this section, there are 2 options to choose from
• Report a data Security Breach – Then follow instructions Section 55 breach – unlawful use of personal data Complete the relevant section
• The ICO will report back to Affino should any further information / action be required

 

Reporting Policy to other persons / organisations

 

Affino will inform the individual concerned regarding the data breach and the action taken. This will be actioned within 72 hours.

 

Affino will also decide whether other persons / organisations need to be informed of the breach. This may include the client or any other parties involved.

 

 

 

Action Required after any breach

 

All data breaches will be discussed at Senior Management level and action taken to prevent any recurrence.

 

These actions will be documented and monitored on an ongoing basis to ensure and such breach s not repeated.

 

If staff discipline is required, they will be referred to HR processes.

 

If the ICO do require any further action, all Senior management will be advised, and relevant action taken and be fully documented.

 

Monitoring & Training

 

Affino will ensure that there are monitoring processes in place to identify and prevent and data breaches.

 

Affino will ensure that all staff are adequately trained on data protection and on how to identify and prevent data breaches within their particular roles.

 

The above is fully documented.