Ormonde Technologies (SurfBox) Ltd (‘the Company’) needs to collect user data (information) for limited purposes from users of its services in public libraries, shopping centres, airports, hotels and other public venues hosting its services. The purpose of processing user data is for the delivery of internet, print and copy services at these venues. Data Protection is the safeguarding of the privacy rights of individuals in relation to the processing of user data.
This is a statement of the Company’s commitment to protect the rights and privacy of individuals in accordance with the General Data Protection Regulation (GDPR).
The Company will administer its responsibilities under the regulation in accordance with the stated data protection principles as follows:
The Company will obtain and process user data fairly and in accordance with the fulfilment of its functions. The user data obtained during the fulfilment of its functions are as follows:
The Company will keep data for purposes outlined in the previous section that are specific, lawful and clearly stated and the data will only be processed in a manner compatible with these purposes. The Company will not retain or disclose user data for any purpose other than for delivery of its services.
The Company will take appropriate security measures against unauthorised access to, or alteration, disclosure or destruction of, the data and against their accidental loss or destruction. The Company is aware that high standards of security are essential for all personal information.
The Company will only retain data for the duration of its service delivery and for any support purposes relating to the services. Specifically, data is retained temporarily for the purposes outlined in Section 1 as follows:
The Company has overall responsibility for ensuring compliance with the Data Protection regulation. However, all employees of the Company who collect and/or control the contents and use of user data are also responsible for compliance with the Data Protection regulation. The Company will provide support, assistance, advice and training to all staff to ensure it is in a position to comply with the legislation. The Company has appointed a Data Protection Officer who will assist the Company and its staff in complying with the Data Protection legislation.
This Statement supports the provision of a structure to assist in the Company’s compliance with the Data Protection regulation, including the provision of best practice guidelines and procedures in relation to all aspects of Data Protection.
This Statement will be reviewed regularly in light of any legislative or other relevant indications.
This document was last updated on Thursday 11 January 2018.