Data protection policy
● Policy prepared by: 5th May 2018
● Approved by management on: 20th May 2018
● Policy became operational on: 20th May 2018
● Last review date: Last review date November 2022
● Next review date; 1st January 2023
Introduction
WasteAction Resource Efficiency Ltd are the parent company of a web service product called the
Warp It Reuse Network. The Warp It Reuse Network is used to redistribute surplus assets between
users of the system. need to gather and use certain information about individuals for the effective
redistribution of surplus assets.
Large institutions instruct their staff to join the service. To join the service staff input their
work address and email as well as their full name.
This policy describes how this personal data will be collected, handled and stored to meet the
company’s data protection standards — and to comply with the law.
Why this policy exists
This data protection policy ensures WasteAction Resource Efficiency Ltd:
● Practises excellent data management
● Complies with data protection law and GDPRS and follow good practice
● Protects the rights of staff, customers and partners
● Is open about how it stores and processes individuals’ data
● Reduces the risks of a data breach
Data protection law
The Data Protection Act 2020 describes how organisations — including WasteAction Resource Efficiency 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 Data Protection Act is underpinned by eight important principles.
These say that personal data must:
1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
GDPR
Replaces. Data Protection Directive. Current legislation on 25th May 2018
The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on
data protection and privacy for all individuals within on the European Union. It addresses
the export of personal data outside the EU.
People, risks and responsibilities
Policy scope
This policy applies to:
● The head office of WasteAction Resource Efficiency Ltd
● All staff of Waste Action Resource Efficiency Ltd
● All contractors, suppliers and other people working on behalf of Waste Action Resource Efficiency Ltd
It applies to all data that the company holds relating to identifiable individuals. This includes, for the company:
● Full names of Individuals
● Work postal addresses
● Work Email addresses
● Work Telephone numbers
Responsibilities
Everyone who works for or with WasteAction Resource Efficiency Ltd has
responsibility for ensuring data is collected, stored and handled appropriately.
Each staff member that handles personal data 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 Directors is ultimately responsible for ensuring that Waste Action
Resource Efficiency meets its legal obligations.
● The Data protection Officer, Alexandra O’Connor, is responsible for:
o Keeping the management updated about data protection responsibilities, risks and issues.
o Reviewing all data protection procedures and related policies, in line with an agreed schedule.
o Arranging data protection training and advice for the people covered by this policy.
o Handling data protection questions from staff and anyone else covered by this policy.
o Dealing with requests from individuals to see the data Waste Action Resource Efficiency Ltd holds about them (also called ‘subject access requests’).
o Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
● The software development company 3rd party supplier, Eightlegged.com, is responsible for:
o Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
o Performing regular checks and scans to ensure security hardware and software is functioning properly.
o Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
o Considering any issues that relate to the running of the system and usability of the site.
● The server management company Microsoft Azure, is responsible for:
o The security and management of the server where Warp It data is help for WasteAction Resource Efficiency Ltd.
● The Marketing Manager, Daniel O’Connor, is responsible for:
o Approving any data protection statements attached to communications such as emails and letters.
o Addressing any data protection queries from journalists or media outlets like newspapers.
o 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 are those who need it for their work.
● Data is not shared informally. All data is accessed only by those employees who need it to maintain the effective running of the service.
● WasteAction Resource Efficiency Ltd provides training to all employees to help them understand their responsibilities when handling data.
● Employees keep all data secure, by taking sensible precautions and following the guidelines below.
o In particular, strong passwords must be used (and never be shared).
o Personal data will not be disclosed to unauthorised people, either within the company or externally.
o When working with personal data, employees must ensure the screens of their computers are always locked when left unattended.
o Personal customer data will not be shared informally. In particular, it will in most cases, not be sent by email, unless to comply with the running of the contract.
o Email accounts and all other cloud services used by WasteAction Resource Efficiency Ltd are accessed via strong password and 2FA.
o Customer Personal data will never be transferred outside of the European Economic Area.
o Employees will not save copies of personal data to their own computers. Always access and update the central copy of any data.
● Data will be reviewed and updated if it is found to be out of date. If no longer required, it will be deleted and disposed of.
● Employees will request help of their data protection officer if they are unsure about any aspect of data protection.
Data storage
Data is will not be stored on paper. There is no manual storage of any data of any kind.
All data is stored electronically only.
● The WasteAction Resource Efficiency Ltd It offices are not customer facing and as such do not have
unauthorised people entering of leaving at will, however if in the rare circumstances that an unauthorised
person does enter, a workperson for example then all screens are removed from sight.
● Data is protected from unauthorised access, accidental deletion and malicious hacking attempts:
● Data is protected by strong passwords (and 2FA where possible) on the individual computers,
that are changed regularly and never shared between employees.
● Data is not stored on removable media (like a CD or DVD)
● Data will only be stored on designated drives and servers in the cloud, and is only uploaded to an approved cloud GDPR compliant computing services. (See below)
● Data is be backed up frequently. (See below)
● Data is never be saved directly to laptops or other mobile devices like tablets or smart phones.
● All servers and computers containing data are protected by approved security software and a firewall.
Hosting Provider & Data Access, Security, Log in, Segregation & Encryption
The hosting provider is WasteAction Resource Efficiency Ltd.
Data is stored in the cloud with Microsoft Azure SQL server.
Data is only accessible through an Azure Private Endpoint encrypted via Transparent Data Encryption (TDE).
Data is shared with WasteAction Resource Efficiency (Warp It) staff. Sub contractor Eightlegged.com who have built and maintain the system and are responsible for the information security- however do not access data.
We store the name and work email address for log in purposes and account management issues.
There is a separation of data storage from the web facing server.
We use Azure Key Vault the manage encryption keys.
Encryption & Network Security
Data is hosted on Microsoft Azure in the UK south and replicated on UK west.
Data is encrypted at rest via TDE, physical files are protected via BitLocker. Server principals are set for specific required functions and passwords stored in an Azure Key Vault.
All data transiting networks is transmitted via TLS 1.3, passwords are stored as salted, 256 AES encrypted text. The database and transiting data is encrypted at rest via TDE, physical files are protected via BitLocker.
Password Policy (Access control & Password management)
Password management is carried out and audited on all principal accounts. Enforced password expiry and complexity on ALL server principals.
All default passwords are updated on all new hardware.
If any passwords are compromised, as soon as this becomes known staff change passwords.
All web services that we use for business operations are Multi factor authenticated.
All passwords must be strong and are in excess of 8 letters. All passwords are stored in a password manager.
Staff access to data is limited physically where ever possible. The system is also 2 Factor Authentication. In the day to day managing of the service, 4 staff members have access to database including customer name, email and work address. Staff are trained in password management and account access procedures.
Authorised Person has admin rights in all hardware and software within the business. No member of staff may install any new software.
User access
Access is via password set by the users, we currently have no plans to install 2FA for standard users, but administrator must use 2FA to log into the portal.
We do not currently employ complex password management for standard users, we have implemented this in the past and our user base did not appreciate it. The security principal level of a standard user poses little risk to data.
Business Continuity & Disaster Recovery
Please see below for business continuity & disaster recovery options available as part of the standard services.
WasteAction Reuse Portal (Warp It) Backup Policy
Introduction
Warp It by WasteAction Resource Efficiency Ltd is committed to managing its customers records including regular backups and archives.
Definitions - To back up data is to copy to another medium or storage so that, if the active data is lost, it can be recovered in a recent if not completely current version.
Backup is primarily intended for disaster recovery, and the assumption is that in most cases the backed-up data will not be read.
Policy
The objectives of this Policy are to:
● identify and store records of transactions on the Warp It exchange system.
● keep the records safe and secure
● take all necessary steps to ensure the safety and security
● describe access arrangements
Back up management
The files which are backed up are
● All company portal transactions
● Uploads of items/ resources (photos etc)
● User transactions within and between organisations
● All transactions details including the financial and environmental reporting values.
● Log in records
● Company account settings
● User account settings
Where data contains personal information- for example the user account area, there is only one master file and one backup copy.
Backup of data
WasteAction Resource Efficiency Ltd maintains backups of the data specified above.
We use Azure Backup Centre, with a site recovery vault and a recovery server based in in a different region.
The database runs full backups every week, differential backups every 12 hours, and transaction log backups every 5 to 10 minutes. We store data in geo-redundant storage blobs that are replicated to a paired region. File backups are performed every 8 hours.
At the end of the contract the organisation admin can download their data from the system. There is no additional end of contract arrangements to return data. At an agreed end of the contract all personal data will be purged from our system immediately. In the case of a user simply not paying an invoice and their account expiring there is a 3 month grace period before all personal data is purged.
Access Policy
The administrator for each portal can download transaction data at any time in the settings dashboard. Administrators can view all transaction details from this tool.
Access to additional data on customer portals can be made by emailing dataprotection@getwarpit.com with 14 days notice and specific data required.
Data accuracy
The law requires Waste Action Resource Efficiency Ltd to take reasonable steps to ensure data is kept accurate and up to date.
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.
● Data will be held in as few places as necessary. Staff will not create any unnecessary additional data sets.
● Staff will take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
● Waste Action Resource Efficiency Ltd will make it easy for data subjects to update the information Waste Action Resource Efficiency Ltd holds about them. For instance, via the company website.
● Data will 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.
Furthermore, if an individual account is inactive for 24 months, if after unactioned notifications then the account is deleted. signs up to the system. In the same way- if the system begins to get bounce back emails from an account. The account will be deleted after unanswered notifications.
Subject access requests
All individuals who are the subject of personal data held by Waste Action Resource Efficiency 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.
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 dataprotection@getwarpit.com. The data controller can supply a standard request form, although individuals do not have to use this.
Individuals will be charged £10 per subject access request. The data controller will aim to provide the 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 Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Waste Action Resource Efficiency 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 where necessary.
To complete transactions with third parties, in this case, other approved Warp It institutions for the express purpose of reusing surplus assets, we will share personal data. Notably this will only include collected data of Full Name and works email address
We also collect transactional data for reporting. This will not include any personal data and is just the KPI gathered within the processes of the system. This data may be used by WasteAction Resource Efficiency Ltd and other third parties for promotion, reporting and press releases. There is no licence agreement needed for this kind of data sharing. If you would like to know more about the data included then please refer to https://www.getwarpit.com/report-guide
Providing information
WasteAction Resource Efficiency 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
To these ends, the company has a privacy policy, setting out how data relating to individuals is used by the company.
This is available on request. And a copy of this policy is also available on the company’s website at https://www.getwarpit.com/policy
Data Breach resolutions
Common Issues/ Questions
Identifying and monitoring unauthorised users and unapproved behaviour from approved users.
Definition
Authorised users are those who have been approved by the administrator in the customer organisation. Unauthorised users are those who have not been approved by any admin and are accessing the system illegally and outside of the Warp It T&C’s.
Please note: In some cases there could be attacks by authorised users (disgruntled staff for example).
Collected data
The following collected data is the limit of our data collection for our customers. We do not collect or require any sensitive data.
● work email address
● work address
● work telephone number
● encrypted password
Passwords are stored, but they are protected by a cryptographic hash function.
Records of user trades of surplus items are also stored. This data is stored only and is not shared in anyway.
Customer data is never transferred to laptop, netbook or other portable devices either as part of the normal operation of the service or as part of the development or maintenance of the service.
Unauthorised access; What do we monitor for?
Networks and computers are monitored and usage logged. Logs are kept secure and are only available to personnel authorised by Warp It and will only be kept as long as necessary in line with current data protection guidelines. As of May 5th 2018 we deem it necessary to retain customer data within the Warp It portal for up to 3 months after the contract ends. This means there is no loss of record data or transaction report data if either the customer returns to their subscription within 3 months or there is an issue that needs to be resolved. After this time the data regarding the individual will be removed and replaced by non identifying code thus retaining the transaction data.
Warp It and our Software Partner Eightlegged.com networks and access records are monitored and logged for all lawful purposes including: -
● Ensuring use is authorised
● Management of systems
● Protecting against unauthorised access
● Verifying security procedures
● System and operational security
● Compliance with Warp It terms and conditions
● Detection and prevention of crime
How do we know when unauthorised access happens?
● Logs for all hardware, physical security, applications and databases are collected centrally and monitored for unusual behaviour.
● All events that fall outside of the 'normal' threshold are emailed to the on call engineer.
● Short term auto banning systems are in place for user accounts and IP addresses that perform unusual activity.
● There is an escalation process in place for all urgent incidents
The Data Protection Officer (from Warp It and/or Eightlegged.com) may do so through any unusual activity and monitoring of logs. Events are monitored and alerts raised when unusual activity occurs.
System administrators may do so by observing suspicious system behaviour. Any member of the Warp It community may identify a potential security incident though external complaint/notification, or other knowledge of impermissible use or disclosure of Data.
The aim of our intruder detection system is to actively monitor for unusual or suspicious behaviour. Warp It monitor this in several ways, by automated systems that track and analyse behaviours patterns in logs or system usage. Remediation can range from temporarily ban users and IP ranges based on suspicious activity, and by hands on intervention and analysis to higher level events. Objectives of the intruder detection system are
● Actively search for signs of unauthorised intrusion
● Prevent or detect the confidentiality of Warp It data on the network
● Preserve the integrity of Warp It data on the network
● Prevent unauthorised use of Warp It systems
● Keep hosts and network resources available to authorised users
● Increase security by detecting weaknesses in systems and network design early
How will we notify you of a security breach?
Our internal security breach process is summarised below.
The Warp It engineer from eightlegged.com responsible for support of the system is expected to:
● Report the attack to Alexandra O’Connor Data Protection and Daniel O’Connor CEO at Warp It.
● Block or prevent escalation of the attack
● Investigation of the incident and preservation of evidence
● Daniel O’Connor (Warp It) to report incident to customer within 24 hours via phone (or some other method at the customers request)
● Repair the resultant damage to the system
Any suspected intrusions, suspicious activity, or unexplained erratic behaviour will be reported to the customer within 24 hours by a communication method of their choice.
Customers administrators are also expected to report any suspicious activity as soon as it is recognised.
Who will have access to your data?
Staff within WasteAction Resource Efficiency.
The administrator in the institution can download transaction data at any time in the settings dashboard. Administrators can view all transaction details from this tool.
Access to additional data on customer portals can be made by emailing dataprotection@getwarpit.com with 14 days notice and specific data required.
Disaster Recovery Recovery Time Objective (RTO).
RTO depends upon the nature of the incident. Software failure is within one working hour, hardware failure within 8 working hours. Security or Attack incident, RTO is dependent upon the securing assets and investigation of the incident. No enchanted service is available.
Standard RPO (Recovery Point Objective) can be expectedto be 20 minutes for database, 8 hours for files. No enchanted service is available.
We have a timescale based policy. Critical – immediate – High with 24 hours – medium within 7 days – Low within 14 days.
We offer 99.9% uptime. Unless critical updates to our service are performed at a weekend, out of office hours. Any planned downtime will be notified to users 7 days prior to action, We run our service on Azure VM and any planned downtime should now be limited to a very short period of time.
Security auditing and actions
We run a monthly external Penetration test by Intruder.IO, and we run Qualys internally on our server.
We invite all customers to penetration test the system.
We run 3rd party independent penetration tests every 18 months, results are available on request.