Context and overview
Introduction
Universal Company Incorporations Ltd – a holding company which encompasses the following websites: Open A European Company.com, Start An American Company.com, Open A Dubai Company.com, Start an Australian Company.com, Open A German Company.com, Open An Italian Company.com and Readymade Companies Worldwide.com – needs to gather and use certain information about individuals and companies.
These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards – and to comply with the European Union (EU) General Data Protection Regulation (GDPR).
The processing of personal data in accordance with these Regulations is lawful and necessary for the prevention of money laundering, terrorist financing or proliferation financing and is for the performance of a task carried out in the public interest.
Why this policy exists
This data protection policy ensures Universal Company Incorporations Ltd:
- Complies with data protection law and follow good practice
- Protects the rights of staff, customers and partners
- Is open about how it stores and processes individuals data
- Protects itself from the risks of a data breach
Data protection law
The GDPR describes how organisations – including Universal Company Incorporations Ltd. – must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The GDPR is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary or five years from the end of the business relationship
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside the EU unless that country or territory also ensures an adequate level of protection or the client has given authorisation for the information to be transferred outside of the EU.
People, risks and responsibilities
Policy scope
This policy applies to:
- The head office of Universal Company Incorporations Ltd
- All branches of Universal Company Incorporations Ltd and its associated companies
- All staff and interns of Universal Company Incorporations Ltd
- All contractors, suppliers and other people working on behalf of Universal Company Incorporations Ltd.
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Plus any other information relating to individuals
Data Protection Risks
This policy helps to protect Universal Company Incorporations Ltd from some very real data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately
- Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data
Responsibilities
Each time that Universal Company Incorporations Ltd handles personal data, it must ensure that it is handled and processed in line with this policy and data protection principles.
However, these people have key areas of responsibility:
- The board of directors is ultimately responsible for ensuring that Universal Company Incorporations Ltd. meets its legal obligations.
- The data protection officer is responsible for:
- Keeping the board updated about data protection responsibilities, risks and issues
- Reviewing all data protection procedures and related policies, in line with an agreed schedule
- Arranging data protection training and advice for the people covered by this policy
- Handling data protection questions from staff and anyone else covered by this policy
- Dealing with requests from individuals to see the data Universal Company Incorporations Ltd. holds about them (also called “subject access requests”).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
- Our external IT company is responsible for
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software is functioning properly
- Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
- The Managing Director is responsible for:
- Approving any data protection statements attached to communications such as emails and letters
- Addressing any data protection queries from journalists or media outlets like newspapers.
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
General staff guidelines
- The only people able to access data covered by this policy should be those who need it for their work.
- Universal Company Incorporations Ltd will provide training to all employees to help them understand their responsibilities when handling data
- Employees should keep all data secure, by taking sensible precautions and following the guidelines below
- Personal data should not be disclosed to unauthorised people, either within the company or externally
- Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
- Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
Data Storage
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
- When not required, the paper or files should be kept in a locked drawer or filing cabinet.
- Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
- Data printouts should be shredded and disposed of securely when no longer required
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data is protected by way of a locked computer screen
- If data is stored on removable media (Like a CD or DVD), these should be kept locked away securely when not being used
- Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service.
- Data should be backed up frequently.
- All servers and computers containing data should be protected by approved security software and a firewall – this is maintained by our external IT support company.
Data retention
As per our Due Diligence policy, data from our clients will be kept according to The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
Our role and responsibilities in relation to this data are clarified during the application process and application form. Data held for marketing purposes (e.g. through email newsletter signup) is held indefinitely.
Subject access requests (see below) can be made to receive a copy of this data and request its deletion by revoking previously held permission. UCI Ltd may be legally obligated to retain this data based upon The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and other related legislation.
Data Use
Personal data is of no value to Universal Company Incorporations Ltd unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
- When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally.
- We will be using a password protected Zip file for data that is sent to our suppliers
- Personal data should never be transferred outside of the EEA (European Economic Area) unless the client has authorised expressly for the undertaking of his/her company incorporation and in line with country AML procedures to identify the client as defined by our internal AML policy and application form for purposes of incorporating a company or opening a bank account.
The more important it is that the personal data is accurate, the greater the effort Universal Company Incorporations Ltd. should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
- Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call
- Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
- It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months. We have an external web marketing company Gooey Digital Ltd who support us for this.
Subject access requests
All individuals who are the subject of personal data held by Universal Company Incorporations Ltd are entitled to:
- Ask what information the company holds about them and why
- Ask how to gain access to it
- Be informed how to keep it up to date
- Be informed how the company is meeting its data protection obligations
- Request the deletion of this data based on the revocation of consent
If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the data controller at heather@uci-ltd.com.
Individuals will not be charged per subject access request unless UCI Ltd can provide evidence of a significant administrative burden posed by the request. The data controller will aim to provide relevant data within 14 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
Disclosing data for other reasons
In certain circumstances, the GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Universal Company Incorporations Ltd. will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers as appropriate.
Providing information
Universal Company Incorporations Ltd. aims to ensure that individuals are aware that their data is being processed, and that they understand:
- How the data is being used
- How to exercise their rights
The above privacy statement lays out all of these responsibilities, and sets out how data relating to individuals is used by the company. We also provide a short form version of this policy for immediate access on all forms which require the submission of personal data.