1. Purpose
This Data Protection Policy outlines Controltech EA Limited’s commitment to protecting personal data in accordance with the applicable Data Protection regulations. It establishes the principles, roles, and practices to ensure personal data is handled lawfully, fairly, and transparently.
2. Scope
This policy applies to all employees, contractors, and third-party partners of Controltech EA Limited who collect, access, use, store, or otherwise process personal data under Controltech’s EA Limited’s control.
3. Definitions
- Personal Data: Any information relating to an identified or identifiable natural person.
- Data Subject: The individual to whom the personal data relates.
- Processing: Any operation on personal data including collection, storage, use, sharing, and destruction.
- Data Controller: The entity that determines the purpose and means of processing personal data.
- Data Processor: The entity that processes personal data on behalf of a controller.
4. Data Protection Principles
Controltech EA Limited adheres to the following data protection principles:
- Lawfulness, Fairness, and Transparency: Has privacy Notices in place for its customers and employees
- Purpose Limitation: Data collected for specific, explicit purposes captured through our data mapping.
- Data Minimization: Only data necessary for purposes is collected.
- Accuracy: Ensuring data is accurate and kept up to date.
- Storage Limitation: Retain data no longer than necessary as per our data retention policy.
- Integrity and Confidentiality: Protect data against loss, misuse, or unauthorized access.
- Accountability: Demonstrate compliance with data protection obligations.
5. Lawful Basis for Processing
Personal data must be processed only if one or more of the following lawful bases apply:
- Consent
- Performance of a contract
- Legal obligation
- Vital interests
- Legitimate interest
6. Roles and Responsibilities
- Management: Ensure adequate resources and oversight.
- Internal Data Protection Lead: Coordinate compliance efforts internally working closely with the external consultant.
- External Data protection consultant: Supports the organization with our data protection compliance program.
- IT Manager: Takes the lead on ensuring adequate safeguards are in place and continually enhanced.
- All Staff: Follow this policy and complete data protection training annually.
8. Data Security Measures
Controltech EA Limited implements appropriate technical and organizational measures including:
- Firewalls, antivirus software and endpoint security
- Encryption and secure storage
- Password management, Data Access controls and role-based permissions
- Regular data backups and disaster recovery protocols.
- Physical office security
- Employee awareness and confidentiality agreements
9. Data Subject Rights
Controltech EA Limited respects and enables the following rights:
- Right to access personal data
- Right to rectification
- Right to erasure (“right to be forgotten”)
- Right to restrict or object to processing.
- Right to data portability
- Right to withdraw consent
- Right to lodge a complaint with the ODPC
10. Data Sharing and Transfers
Data may be shared with:
- Authorized third parties under contractual safeguards.
- Clients (where Controltech acts as a processor).
- Regulators or law enforcement if legally required Cross-border transfers are safeguarded using contracts or adequacy decisions.
11. Data Retention and Disposal
Personal data is retained only as long as necessary. Once no longer required, it is securely deleted or anonymized according to our Data Retention and destruction Policy and Schedule.
12. Breach Management
Controltech EA limited maintains a breach response plan. All data breaches must be reported immediately to the Data Protection Lead. Serious breaches are reported to the ODPC within 72 hours where applicable.
13. Policy Review
This policy will be reviewed annually or when significant changes occur in legislation or operations.
14. Contact
For questions or concerns regarding this policy, contact:
Internal Data Protection Lead
Email: info@controltech-ea.com