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PURPOSE POLICY

All employees of UNIVERSAL RELOCATIONS who process personal data must comply with the Data Protection Act of URS.

SCOPE

This Procedure & policy applies to:

  • All branches of UNIVERSAL RELOCATIONS
  • All employees of UNIVERSAL RELOCATIONS
  • All contractors, suppliers and other people working on behalf of UNIVERSAL RELOCATIONS

It applies to all data that the UNIVERSAL RELOCATIONS holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • …plus any other information relating to individuals/customers

RESPONSIBILITIES

All employees of UNIVERSAL RELOCATIONS who process personal data must comply with the Data Protection Act of URS.

Everyone who works for or with UNIVERSAL RELOCATIONS has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

The Top Management is ultimately responsible for ensuring that UNIVERSAL RELOCATIONS meet its legal obligations.

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All employees who deals with data are responsible for:

  • Keeping the board updated about data protection responsibilities, risks and issues.
  • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
  • Arranging data protection training and advice for the people covered by this policy.
  • Handling data protection questions from employee and anyone else covered by this policy.
  • Dealing with requests from individuals to see the data UNIVERSAL RELOCATIONS holds about them
  • Checking and approving any contracts or agreements with third parties that may handle UNIVERSAL RELOCATIONS‘s sensitive data.

The IT personnel, is responsible for:

The sales & marketing personnel, is responsible for:

DATA STORAGE

GENERAL EMPLOYEE GUIDELINES

DATA PROTECTION PRINCIPLES

All personal data must be processed in accordance with the eight Data Protection Principles. The essence of these principles is set out below together with brief, nonexhaustive practical examples of when these principles may have relevance to you.

Personal data must:-

  • Be processed fairly and lawfully;
  • Be collected with the consent of the individual client after explaining the purpose and the necessity of the data. Example- collecting passports,PIO cards etc.,
  • The individual will have the right to refuse the collection or processing of his personal data unless it is required by the Law.
  • Be obtained only for one or more specified or lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes; Example – passports collected from clients should only be used for Customs clearance and not be misused .
  • Be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed;
  • Be accurate and, where necessary, kept up-to-date;with reference to customer content details ,address, phone numbers etc.,
  • Employee must notify changes of name, address, telephone number, bank and marital status to the HR Department soon as possible. The HR Department will endeavor, periodically, to ask employee to confirm that such personal data held by the UNIVERSAL RELOCATIONS is accurate. Employees should advise the UNIVERSAL RELOCATIONS of any changes to their contact details or to any other details that may be of relevance.
  • Not be kept for longer than is necessary, passports or educational certificates to be returned after scan soon as the required task is completed
  • As an example, as an Employee of the UNIVERSAL RELOCATIONS, some parts of your UNIVERSAL RELOCATIONS record may be deleted from computer or destroyed (if manually recorded) at the end of the sixth year following the year in which you leave the UNIVERSAL RELOCATIONS. The reason that the UNIVERSAL RELOCATIONS retains this information is to assist in establishing facts in the event of a dispute.
  • For example, individuals have a right of access to the information that the UNIVERSAL RELOCATIONS holds about them. Upon receipt of a written subject access request UNIVERSAL RELOCATIONS shall disclose all the information that it is required to do so by law
  • If any member of employee receives any letter from a customer, business contact, other employee, Employee or any other third party requesting any
  • information about them then they must pass the letter to the Data Protection Officer immediately.
  • Employees should, if they are making a subject access request of UNIVERSAL RELOCATIONS, send their access request to the Data Protection Officer
  • Access to personal data must be restricted to authorised individuals for approved purposes
  • Be protected by appropriate technical and organisational measures against unauthorised or unlawful processing, against accidental loss or damage.
  • UNIVERSAL RELOCATIONS must take steps to put in place technical methods (i.e. firewalls, encryption, password protection, etc.) or organisational methods (hierarchy of access to personnel files, locking cabinets etc.) of protecting personal data where the importance of the personal data makes this appropriate.
  • All Employees who have access to personal data controlled by the UNIVERSAL RELOCATIONS whether or not on computer, and whether in the office or at home or elsewhere, must take adequate precautions to ensure confidentiality so that neither the UNIVERSAL RELOCATIONS, nor any individual employed by the UNIVERSAL RELOCATIONS, becomes exposed to criminal or civil liability as a result of the loss, destruction or disclosure of personal data. All individuals must fully comply with all UNIVERSAL RELOCATIONS procedures and requirements in this regard.
  • Laptops are particularly vulnerable to theft, especially when used outside of UNIVERSAL RELOCATIONS premises. In these circumstances, employee must keep laptops in their possession at all times unless they have been deposited in a secure location such as a locked closet or a hotel safe.
  • Personal data should not be stored on laptops unless this is unavoidable and appropriate security measures have been implemented following a risk assessment. This will comprise an encryption and security system. These measures will apply to portable data storage media such as DVDs, mini hard disk drives and USB flash memory data sticks. • Personal data must not be transmitted over the Internet unless appropriate encryption methods are used.
  • Personal data must not be sent to a third party on portable storage media or in paper form by conventional post. A secure delivery service must be used.

DATA USE

SUBJECT ACCESS REQUESTS

Subject access requests from individuals should be made by email, addressed to the Data Protection Officer at admin@universalrelocations.com The Data Protection Officer can supply a standard request form, although individuals do not have to use this.

DISCLOSING DATA FOR OTHER REASONS

PROVIDING INFORMATION ABOUT THE POLICY

UNIVERSAL RELOCATIONS aims to ensure that individuals are aware that their data is being processed, and that they understand:

SECURITY

Any breaches of this Procedure in relation to personal data security will result in disciplinary action and, in serious cases, may result in the dismissal or the expulsion of an Employee.

SURVEILLANCE AT WORK

The UNIVERSAL RELOCATIONS has a legitimate interest in monitoring the behavior of its employee and Employees that attend the UNIVERSAL RELOCATIONS. For instance, UNIVERSAL RELOCATIONS may wish to carry out monitoring in order to:

Monitoring can take several forms. It can involve monitoring by way of Closed Circuit Television (CCTV), e-mail and Internet monitoring or telephone monitoring. More detailed information about the monitoring of the Internet and e-mail activity can be found in the UNIVERSAL RELOCATIONS IT Policy. The UNIVERSAL RELOCATIONS holds information on the destination and duration of calls made from the UNIVERSAL RELOCATIONS telephone system and may use this information if misuse of the system is suspected. Below, the UNIVERSAL RELOCATIONS sets out its policy with regard to the use of CCTV cameras.

CCTV CAMERAS

In carrying out such monitoring the UNIVERSAL RELOCATIONS may use CCTV cameras in what are considered to be “public” areas of the workplace. Generally, the use of such CCTV Cameras shall be notified by using suitable signage at obvious places at the entrance to the monitored areas, however, (even in the absence of such signage) Employees and employee should be aware that public space within UNIVERSAL RELOCATIONS premises may be monitored in this way.
The UNIVERSAL RELOCATIONS may also monitor through the use of covert CCTV but it shall only do so where specific criminal activity has been identified. Before starting any use of covert CCTV the UNIVERSAL RELOCATIONS will have made an impact assessment concluding that notifying employees of the use of such covert monitoring would prejudice the investigation and that the use of covert monitoring techniques is a proportionate response to the behavior in question. Where appropriate, (but at its absolute discretion) the UNIVERSAL RELOCATIONS may involve the law enforcement authorities in such monitoring.

PENALTIES

A failure on the part of the UNIVERSAL RELOCATIONS to comply with the Data Protection Principles and the conditions for processing personal data stipulated by UAE Federal Law may result in a court order to correct, erase or destroy inaccurate or out of date personal data or to change the way we process personal data. In addition, the court may award compensation arising from a breach of the Law in some circumstances.
Where an individual suffers damage or loss because of unauthorized disclosure, inaccurate or missing data, or the loss or destruction of data in relation to him/her, he/she may seek compensation from the courts.

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