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 to support 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.IRL@peninsula-ie.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.
||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 and individual components are tested at on a regular basis. All necessary remediation has been carried out.
|Cyber Security and Compliance
||Data Protection and Cyber Security is our #1 priority at Peninsula Group. We hold multiple accreditations and certifications including ISO27001 and Cyber Essentials Plus. We heavily invest in People, Processes and Technology to ensure that the protection of our customer and employee data remains the top priority.
|Software and Applications
- 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 manged and patched centrally and permitted on user machines which is managed through Software Centre.
- Software is then packaged and released. Security and vulnerability testing is integral to the development lifecycle.
- All operating systems in place are fully supported and patched.
- We use desktops and laptops which use Windows 10 with window security updates being installed automatically.
- No sensitive information is stored on non-compliant systems.
- Internal network access is controlled through internal Active Directory security.
- Access to applications is made via https secure internet browsers. Internal systems can only be accessed within the secure Corporate network.
- A strong password policy has been implemented with complexity and Multi-Factor Authentication with Conditional Access to protect against phishing and malware attacks.
- All access is granted on the principle of ‘Least Privileged Access’.
- Remote working is enabled for approved employees and is enabled via secure encrypted VPN with multifactor authentication.
- All Data at Rest and in Transit is encrypted. All databases, software and hardware/devices are protected with high levels of encryption. Encryption keys are managed with strict policies and procedures. The keys are stored in a secure location which is only accessible to database admins.
|Monitoring and Testing
IDS, IDP and SIEM provide monitoring for the network 24/7 and Data Loss Prevention technology and strategies provide protection against accidental and malicious data loss and cyber attacks.
Vulnerability Management and Penetration Testing are integral to our testing strategy.
All patches are governed by the change control process which includes evaluation, testing and deployment.
A standard build procedure ensures that all default admin and back door accounts are removed.
- We update systems in line with Microsoft and Cyber Security best practices to ensure that all systems are patched and that we are always using the most advanced technical and organisational controls and tools available.
|Data Back Ups
- Data is backed up daily to redundant backup locations and all backups are encrypted.
- 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.
- 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 EPP & EDR 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 including SIEM, IDS and 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.
- Enterprise Security Monitoring has been implement for 24/7 visibility & protection.
Third Party Security…
- 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 Salesforce which is ISO27001 and PCI-DSS compliant. 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 & Secondary Data centres in the UK. All group data bases reside in a primary and secondary data centre which are both based in the UK.
- Peninsula’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 security plus 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.
- 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 Peninsula Business Services, Block W, Eat Point Business Park, Alfie Byrne Road, East Wall, Dublin 3, Ireland.
GDPR Oversight Team: GDPR@peninsula-uk.com
Data Protection Officer: firstname.lastname@example.org
If you’re not satisfied with our response, or believe we’re not processing your personal data in accordance with the law, you can approach the UK regulator for further guidance at www.ico.org.uk/concerns
This version was last updated and reviewed August 2020.
We regularly review and monitor regulatory guidance for any industry changes which may impact our business operations or your rights and freedoms.
We are legally known as Peninsula Business Services Limited, and our registered office is at The Peninsula, Victoria Place, Manchester, M4 4FB, United Kingdom. We are registered in England and Wales under company number 05445673. ICO Registration Number: Z6085670
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:
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).
Copyright © Peninsula Business Services Limited 2020