We follow the data protection commission’s guidelines on data protection and comply with the EU’s GDPR legislation. Our insurance requires us to have a stringent process in place with regard to data protection.
Spaceship Digital Ltd is committed to protecting your privacy by ensuring that any personal data is collected and used lawfully and transparently. When delivering our professional service, we are the Data Controller of the personal data that you supply to us under your contract with us.
When providing these services, we take our responsibilities regarding data protection very seriously and are bound by all applicable data protection laws in respect of the handling, processing and collection of data. All employees who handle personal and business data are fully trained to ensure that the data is processed in line with the General Data Protection Regulations 2018 (GDPR) as well as The Data Protection Act 2018 (DPA 2018).
Personal data we collect:
The type and frequency of any personal data collected will always depend on how our website and services are used. If you do not wish to provide us with certain categories of personal data, you may not be able to use our services in their entirety.
Personal data provided to us:
We use electronic contact forms and chat facilities across our websites. These forms will prompt users to input basic contact details so we can generate service quotes, provide newsletter updates and respond to enquiries. You may also provide data to us when registering for an event, seminar or vacancy or when corresponding with us by phone, email, letter or social media. It is important that the personal data we hold about you is accurate and current. You should keep us informed if your personal data changes during your relationship with us.
Personal data collected by us:
Where you ask us to provide services, we may be required to process additional categories of personal data relating to you or other parties to ensure the provision of informed legal advice. We may also collect additional data from you as part of our recruitment process, during your employment or when you visit our offices via CCTV. We may also ask to verify your identity in limited circumstances by providing valid photographic identification.
Personal data from other sources:
We may receive information about you and/or your company from specific third parties such as business partners, sub-contractors, advertising networks, analytics providers, hosting providers and search information providers. Spaceship also receives referrals from other clients and purchases marketing lists from external companies.
When you visit our website, a record of your device’s IP address is retained which is used anonymously in order to determine website and page visitors.
Before processing any personal data, we ensure that at least one lawful basis under GDPR is met. We will not disclose personal data for any purpose other than what the data was originally collected for; unless there is an overriding legal basis that enables this processing.
We may collect, hold, use and disclose the information collected to compile statistical data and to maintain our database; to develop or improve our website; respond to any queries; notify you of any upcoming marketing, training or other events that we think may be of interest to you; provide you with publications; manage quality control and compliance issues; manage systems administration; provide you or your organisation with advice; notify you about important changes or developments to our services; contact you for your views on our services or to determine the suitability for employment.
We may also process your personal data in the following circumstances:
To Perform Our Service Under the Contract:
We process information in order to support and maintain our existing or potential contractual relationships under the lawful basis ‘performance of a contract’. We may process personal data in order to provide various supporting client services, take payments and to make improvements to our website. We record all calls made to our staff members including internal, inbound or outbound calls. The lawful basis which we often rely on to process data for the duration of servicing on your account and for the decision to enter an initial or any subsequent contract is under our ‘legitimate interests’. Ensuring our administrative and IT systems are secure and robust against unauthorised access also falls under this basis.
For Fraud Prevention:
Due to the products we offer to companies, we also have a ‘legal obligation’ to validate the status of companies we work with which may involve identifying and verifying individual data subjects as part of our ‘legitimate interests’ to safeguard against criminal or fraudulent activities. We also need to ensure that VAT and premium tax is paid.
To Defend Legal Issues:
We have a ‘legitimate interest’ to process data which may assist us in connection with the establishment, exercise or defence of legal claims.
To Process Sensitive Data:
In some cases, where the processing is deemed high risk or highly sensitive, we may ask for your ‘consent’ before we undertake the processing. For example, when providing information on reasonable adjustments before an interview. Where consent is used as the lawful basis for the processing, you will be entitled to withdraw that consent at any time as well as exercise your data privacy rights.
When you apply for a vacancy:
You provide several pieces of data to us directly during the recruitment exercise. In some cases, and to facilitate our ‘Legitimate Interests’ we will collect data about you from third parties, such as employment agencies and former employers when gathering references or credit reference agencies. Should you be successful in your job application, we will gather further information from you, for example, your bank details and next of kin details, once your employment begins. We have a Legal Obligation to ensure you have a right to work in the EU and make reasonable adjustments for you if you have a disability. The ongoing lawful basis we rely on to process your data will be under our legal obligations or legitimate interests which may include assessments made on salary.
For Marketing Purposes:
As part of our business-to-business sales strategy, we may contact companies and individuals about our products and services. To do this, we rely on our shared ‘legitimate interests’ in doing business together. This lawful basis also applies to any purchased data we may use from our various lead sources.
Your Data Privacy Rights
All data subjects have individual rights. On a case by case basis, you have the following rights in relation to your personal data processed by Spaceship Digital Ltd:
- The right to be informed about how your personal data is collected and used
- The right to request access to a copy of any personal data that we hold about you
- The right to rectify personal data we may hold which is identified as incorrect or misleading
- The right to erasure of any personal data; also known as ‘the right to be forgotten’
- The right to restrict further processing of your personal data
- The right to data portability where technology allows us to send personal data onto a new controller
- The right to object to the processing or certain processing activities
- Rights in relation to automated decision-making including profiling.
As an organisation, we do not operate any automated decision-making systems. Please be aware that the rights listed in this section only apply to individuals and cannot be used to request data relating to business entities. Please be aware that your rights of access do not entitle you to physical or digital copies of any documentation we hold.
Below are GDPR principles in which 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 efficiently with any access requests we may receive.
Data Integrity and Confidentiality: We hold data on secure systems. We use Google for email so data servers are based in the EU and fully compliant with GDPR requirements. Our hosting partner uses Google Cloud servers that are also based in the EU and are fully compliant with GDPR requirements.
Information security and integrity is key to our smooth operation. We have an Incident Response Team with our hosting and email server providers 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 below explains our stance on different operational areas of our business, so that you can easily see the standards we work by.
Software and Applications:
Software applications are managed through standard Agile software development 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..
No sensitive information would be stored on non-compliant systems.
Internal network access is controlled through internal Active Directory security.
Access to software and websites is accessed via https secure internet browser.
Passwords on devices are changed every 90 days and complexity requirements are enforced.
All access is controlled by ADS permissions and limited access.
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 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.
Monitoring and Testing:
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 are 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.
Security monitoring has also been deployed.
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 that 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 system is called Monday.com and we can confirm that they also have a dedicated security team which regularly tests and verifies that all controls are operational.
Monday.com is GDPR compliant, you can read more about it here – https://monday.com/l/privacy/monday-com-is-gdpr-ready/
Spaceship’s data is segregated from other Monday.com customers.
All staff and freelancers are screened prior to their engagement and interviews are face to face where possible.
Anyone who works with Spaceship will have statements and qualifications checked for validity before the offer of employment can commence.
We update our staff and freelancers when additions and updates are made to any privacy policies.
A restrictive covenant is signed by staff and freelancers prior to employment and a confidentiality agreement is signed on the first day of employment.
Staff and freelancers are expected to change their passwords regularly and we enforce complex password requirements.
When an employee or freelancer leaves the business, all accounts and access is suspended immediately, blocking all access to our systems.
If working remotely from a shared office space, 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.
All data retention is handled in line with our retention policy. We are committed to 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.
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 used when necessary for printed documents, after use.