GDPR Principles we Operate by
Accountability: We are committed to the principles of the GDPR by adopting the concept of ‘data privacy by design’ within our operational model. We remain accountable by having detailed policies and systems in place as well as a Data Protection Officer to oversee our overall compliance to data protection regulations including the management of access rights requests. Our policies are regularly reviewed and updated, and our staff are periodically trained on data protection and security throughout the year.
Transparency, Fairness and Lawfulness: We process data with data subjects’ interests in mind and ensure that we approach processing activities with transparency to maintain fairness in what we do. This way we can be sure that we are processing data lawfully. We have a robust process in place to allow us to deal efficient with any access requests we may receive.
Data Integrity and Confidentiality: We hold data on secure systems, and we are IS027001 and cyber essentials plus certified. We can provide evidence of our certifications on request. Information security and integrity is key to our smooth operation and we have dedicated cyber security team who protect our systems. We also have an Incident Response Team on hand tosupport us in the event data may become compromised.
Data Minimisation and Data Storage: We will not keep data for longer than is necessary and only keep data if there is a lawful basis which allows fair retention. When we do need to remove data from our possession, we do so by using industry approved standards so the disposal or anonymisation is thoroughly compliant.
Data Accuracy: Keeping data accurate is very important to us and we train our staff to ensure they are maintaining data to a high quality and with all the facts available.
Purpose Limitation: We use the data we attain for a specific purpose. This means that data is not processed for any alternative reasons other than what the data was originally collected for.
The tables below explain our stance on different operational areas of our business, so that you can easily see the standards we work by.
If you have any further queries about any topics raised in this document please contact our Data Protection Officer on GDPR@graphitehrm.com for further assistance and clarity.
Physical Security of our Sites
||Reception areas are staffed 24/7 and door access control systems are in place throughout the building and all entrances are monitored by
CCTV including the data centre.
||Secure access areas are protected by entry controls to ensure only authorised staff can enter via an access control card. Access rights are removed when staff move roles and access rights are limited to necessary personnel required.
||A BCP/DR policy has been implemented. A full annual DR test is conducted within salesforce (our CRM provider) and individual components are tested at Graphite HRM on a regular basis. All necessary remediation has been carried out.
- Software applications are managed through a standard Agile software develop methodology. Once a change is completed, end to end testing is performed to ensure the accuracy of the change and the existing system functionality.
- Only approved software is managed and patched centrally and permitted on user machines which is managed through Software Centre.
- Software is then packaged and released.
- All operating systems in place are fully supported and patched.
- We use desktops and laptops which use Windows 10 with window updates being installed automatically.
- Sensitive data is processed on several systems including salesforce.
- No sensitive information would be stored on non-complaint systems
- Internal network access is controlled through internal Active Directory security.
- Access to Salesforce is accessed via https secure internet browser.
- Internal systems can only be accessed within the secure Corporate network.
- Passwords on devices are changed every 90 days and complexity requirements are enforced.
- All access is controlled by ADS permissions and limited access given.
- All remote access via remote working employees is secured by VPN log on technology and you are unable to access the networks unless a secure VPN connection has been established.
- All databases, software and hardware/devices are protected with high levels of encryption. Encryption keys are managed with strict policies and procedures. The key is stored in a secure location which is only accessible to database admins.
- On our equipment all patches are governed by the change control process which includes evaluation, testing and deployment.
- We update systems when the time is appropriate to ensure we are always using the most advanced technical and organisational tools out there.
|Data Back Ups
- Data is backed up daily and a data restore process has been tested.
- Measures are in place to ensure that the business can continue to function should a compromise occur.
- Data is backed up to physical media stored offsite at our secure data backup facility which is owned by the group and secured with CCTV, physical locks and limited access controls.
- The data restore process is tested monthly or as required.
- Performance monitoring and file integrity monitoring is in place to ensure our business continuity plan can take full effect.
- A standard build procedure ensures that all default admin and back door accounts are removed.
- Regular Network monitoring identifies any non-compliance to data loss prevention controls.
- Penetration testing at application and network level is carried out on a regular basis.
- We may use cloud storage facilities for processing and storing data and when we do this, we ensure that the security is maintained and tested regularly.
- Our CRM is built on cloud-based infrastructure.
- All data resides in the EU or UK area and no data is transferred out of the EEA.
- All networks have firewalls, antivirus and malware protection in place which is deployed on all endpoints to detect, alert and neutralise any threats.
- Any applications accessible from the internet are constantly safeguarded to prevent the existence and exploitation of web application vulnerabilities such as cross-scripting or SQL injection.
- External connections are protected with enterprise, resilient firewalls and dedicated security monitoring ex SIEM, IDS, IDP.
- All internet access is controlled by a dedicated web filtering appliance which restricts the types of traffic and URLs.
- Firewalls and monitoring control and monitor traffic entering and leaving the organisation.
- Sensitive data is processed on several systems including salesforce.
- Security monitoring has also been deployed including a dedicated SIEM platform.
- All contractual IT security requirements are in place with any third parties we use which ensures the relationship remains subject to GDPR compliance.
- Where necessary, our contract with them includes Data Processing Terms or terms are built into our products terms and conditions.
- We also use alternative data protection safeguard mechanisms where appropriate in the form of standard contractual clauses where required.
- Our CRM systems is called Salesforce and we can confirm that they also have a dedicated security team which regularly tests and verifies that all controls are operational.
- All Salesforce data resides in the Primary Data centre in the UK and secondary in Germany. All group databases reside in a primary and secondary data centre which are both based in the UK.
- Graphite HRM’s data is segregated from other salesforce customers.
- All staff are screened prior to their engagement and interviews are face to face where possible.
- All staff get an induction focused on data protection and all our staff’s CV statements and qualifications are checked for validity before the offer of employment can commence.
- Each staff member is issued with an Employee Handbook which we regularly review and update where necessary.
- We update our staff when additions and updates are made.
- A restrictive covenant is signed by staff prior to employment and a confidentiality agreement is signed on the first day on employment.
- All staff receive security training as part of their induction which is reinforced periodically during training sessions and presentations.
- Staff are expected to change their passwords regularly and we enforce complex password requirements.
- When an employee leaves the business, all accounts and access is suspended immediately, blocking all access to our systems and buildings.
- A clear desk policy is in place across the group and staff know to lock screens when they are away from their desks for any period.
- We operate policies for data security for our remote and field workers so that integrity is always maintained.
- Staff are not permitted to store any data via removable media (USB’s) or on device hardware.
Data Retention and Disposal
- All data retention is handled in line with our retention policy.
- We are committed in taking a practical approach in line with legal, contractual and commercial requirements relating to the ownership, retention and disposal of information relating to our business activities within the UK and Ireland. We tend to keep our client data for 7 years until the contract end date.
- As a company we have made a conscious effort to become more digitally focused and we steer away from paper records wherever possible.
- Confidential waste bins are located on each floor for confidential paper waste and this is securely shredded by a vetted third party who provide a certificate of destruction upon completion.
- We have a hardware disposal policy in place which ensures that all hardware is commercially wiped before final destruction via an accredited third party who also provide certificate of destruction.
Queries and Complaints
Our Group Data Protection officer welcomes communication around our policies and practices and they can be directly contacted on the details below, which are also publicly available on the ICO register. You can also write to us at:
East Point Business Park,
Alfie Byrne Road,
Northern Ireland Office:
Citylink Business Park,
GDPR Oversight Team: GDPR@graphitehrm.com
Data Protection Officer: Peninsula Legal Services Ltd t/a Irwell Law. Email: email@example.com
If you are unhappy with the response that you receive from us when you exercise your GDPR rights, you have the right to lodge a complaint to the DPC. More guidance about raising a complaint is available on the DPC’s website https://dataprotection.ie/docs/Raise-aConcern/1716.htm.
This version was last updated and reviewed January 2022.
We regularly review and monitor regulatory guidance for any industry changes which may impact our business operations or your rights and freedoms.
In this privacy notice, “personal data” means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier.
We are legally known as Graphite HRM,
We form part of a larger group of undertakings known as ‘The Peninsula Group’. Other Companies that sit within our Group of companies within the global group:
Peninsula Business Services (UKI and ROI), Croner (UK), Croner-I (UK), Croner Taxwise (UK), Bright HR (UK), Health Assured (UK), Peninsula Employment Services (Ireland), Graphite HRM (Ireland), Employsure (Australia), Employsure (New Zealand), Peninsula Business Services (Canada).
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