Privacy Policy

 Social Media Help is committed to protecting the rights and freedoms of any data subjects and safely and securely processing their data in accordance with all our legal obligations and business.

 We hold personal data about our employees, clients, suppliers, and other individuals for a variety of business purposes needed for the business to work smoothly.

 This policy sets out how we ensure to protect the personal data we gather and ensure that all of our staff understand the rules governing their use of the personal data from our company and other companies to which they have access in the course of their employment.

 This policy requires staff under Social Media Help to ensure that they are taking the appropriate measures before any significant new data processing activity has taken place to ensure that work is not at fault.

The purposes for which personal data may be used by us:

In the personnel, administrative duties, financial information, regulatory, payroll and business development purposes.

 Business purposes:

 We gather information as part of investigations by regulatory bodies or in connection with any legal proceedings or requests this ensures that our business policies are adhered to.

(such as the policies covering email and internet usage for the business).

 ​For also operational reason, such as recording transactions, that help training for all staff members in quality control measures, ensuring the confidentiality of commercially sensitive information within all our work with clients in the business.

We do security vetting to ensure that companies are able to pay and for checking and investigating complaints towards Social Media Help.

 Checking references toward this business, ensuring safe working within the business Social Media Helps work, monitoring, and managing staff access to systems and facilities and staff absences, also within administrational tasks.

 Monitoring staff conduct in the accounts with clients, disciplinary matters with any problems that rise from their time in employment with Social Media Help.

We also monitor the marketing within our business and with the clients, and improving services given to any client.

 Personal data stored

 ‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 Personal data we gather may include:

 Employees or clients for –

 Individuals’ phone number

• Email address
• Educational background
• Financial and paying details for the bank
• Details of certificates and Diplomas of their skills
• Education and skills acquired
• Marital status, nationality
• Job title
• CV of at least 2/3 years of previous employment

 This could include special categories of personal data-

 Racial or ethnic origin

• Political opinions
• Religious or similar beliefs
• Trade union membership (or non-membership)
• Physical or mental health or condition that they are currently in
• Criminal offences or related proceedings that have just finished or ongoing
• Genetic and biometric information

 This will be stored and strictly controlled in accordance with this policy. There will be no access to the data unless it is needing to be accessed. Or the person who requests their own information stored by the business.

Data controller we will allow a Data controller to access this information we have collected if they determine the purpose and means of why they would like to access this information gathered.

Where the purposes and means of such processing are determined by law.
 Data processor

 ‘Processor’ means a natural or legal person, public authority, agency, or other body which gathers personal data on behalf of the controller.

 Processing

‘Processing’ means any operation or set of operations which is performed on personal data or on any sets of personal data, whether or not by any automated means, such as collection, or recording, an organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction to work.

 Supervisory authority

This is the national body responsible for data protection for business. The supervisory authority for our organisation is [the Information Commissioners Office].

 Policy applies to…

This policy applies to all staff, who must be familiar with this policy and comply with its terms and conditions.

This policy supplements our other policies relating to internet and email use in Social Media Help business. We may add or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted in the business. All must read to be familiar with Social Media Helps policies towards any business we do business with.

 Who is responsible for this policy?

Roché Beel has overall responsibility for the day-to-day implementation of this policy for Social Media Help. For further information about this policy if necessary, please ask.

The principles with the EU & UK

 Social Media Help shall comply with the principles of data protection (the Principles) enumerated in the EU General Data Protection Regulation. We will make every effort possible in everything we do to comply with these principles. The Principles are:

1. Are to be Lawful, fair, and transparent to all clients –

Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used within the company.

2. Limited for its purpose on why we use it –

The data can only be collected for a specific purpose and used for a specific purpose. This will be transparent to the business, client or person that it is again.

3. Data collection

Any data collected must be necessary and not unnecessary for its purpose.

4. Accurate when collecting data –

The data we hold must be accurate and kept up to date within the business to make sure that nothing is inaccurate in our data.

5. The holding of records –

We cannot store data longer than necessary; we will delete when the client or business stops a service. This means that the client will have to sign up again and provide that information again so that we are able to comply with our business policies.

6. Integrity and confidentiality within Social Media Help –

The data we hold must be kept safe and secure at all times with any client and employee within the business.

Our accountability and transparency within the business is that we must ensure accountability and transparency in all our use of personal data and we must show how we comply with each Principle of the terms and conditions and privacy policy.

You are responsible for keeping a written record of how all the data processing activities you are responsible for comply with each of the Principles at work.

To comply with data protection laws and the accountability and transparency Principle of GDPR, we must demonstrate compliance with the business.

You are responsible for understanding your particular responsibilities of the job role to ensure we meet the following data protection obligations

– To fully implement all appropriate technical and organisational measures at all times 

– To maintain up to date and relevant with documentation on all processing activities within the business

– Conducting Data Protection Impact Assessments

– Implement measures to ensure privacy by design and default, including:

– Data control with posts
– The processing of personal data
– Transparency of business communication
– Allowing individuals to monitor process any work
– Creating and improving security and enhanced privacy procedures on an ongoing basis for the business to ensure confidentially

 Our procedures

Fair and lawful processing with the business, with all individuals’ rights under the first principle.

This would generally mean that we should not process personal data unless the individual whose details we are processing, has consented to this happening in the first place.

If we cannot apply a lawful basis (explained below), our processing does not conform to the first principle and will be unlawful.

Data subjects have the right to have any data unlawfully processed erased from Social Media Help.

Lawful basis for processing data

We must establish a lawful basis for processing data. Ensure that any data you are responsible for managing has been collected in the correct way.

It is your responsibility to check the lawful basis for any data you are working with and ensure all your actions comply the lawful basis.

At least one of the following conditions must apply whenever we process personal data: 

1. Consent on why we need this-

We hold recent, clear, explicit, and defined consent for the individual’s data to be processed for a specific purpose, within the business. 

2. Contract for employees-

The processing is necessary to fulfil or prepare a contract for the individual working for Social Media Help. 

3. Legal obligation toward employees –

We have a legal obligation to process the data (excluding a contract). 

4. Vital interests –

 Processing the data is necessary to protect a person’s life or in a medical situation. If we do not know the situation at hand we can not help the individual.

We also can not be held responsible for any medical situation if we were not told about this in advance or as soon as the individual knows. 

5. Public function – 

Processing necessary to carry out a public function, a task of public interest or the function has a clear basis in law. 

6. Legitimate interest –

The processing is necessary for our legitimate interests within the business Social Media Help. This condition does not apply if there is a good reason to protect the individual’s personal data which overrides the legitimate interest from an outside party.

Deciding which condition to rely on, when assessing if the assessment is of the lawful basis, you must first establish that the processing is necessary.

This means the processing must be a targeted, appropriate way of achieving the stated purpose, and having documentation to back this on.

You cannot rely on a lawful basis if you can reasonably achieve the same purpose by some other lawful means.

Remember that more than one basis may apply, and you should rely on what will best fit the purpose, not what is easiest in any given situation.

Consider the following factors and document your answers:

Our commitment to the first Principle requires us to document this process and show that we have considered which lawful basis best applies to each processing purpose within the business Social Media Help, and fully justify these decisions within this.

We must also ensure that individuals whose data is being processed by us are informed of the lawful basis for processing their data, as well as the intended purpose within our business. Please check our privacy notice.

This applies whether we have collected the data directly from the individual, or from another source.

If you are responsible for making an assessment of the lawful basis and implementing the privacy notice for the processing activity, you must have this approved by Roché Beel, before proceeding.

Special categories of personal data – 

Sensitive personal data requires more protection. This type of data could create more significant risks to a person’s fundamental rights and freedoms and could for example by putting them at risk of unlawful discrimination. 

The special categories include information about an individual’s:

• race
• ethnic origin
• politics
• religion
• trade union membership
• genetics
• biometrics (where used for ID purposes)
• health
• sexual orientation

In most cases where we process special categories of personal data we will require the data subject’s explicit consent to do this unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work).

Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.

The condition for processing special categories of personal data must comply with the law. If we do not have a lawful basis for processing special categories of data that processing activity must cease within the business unless other information is lawfully supplied. 

The Responsibilities with Social Media Help

 Our responsibilities: 

• Analysing and documenting the type of personal data we hold and making sure is correct and up to date
• Checking procedures to ensure they cover all the rights of the any individual
• Identify the lawful basis for processing data
• Ensuring consent procedures are lawful and transparent
• Implementing and reviewing procedures to detect, report and investigate personal data breaches and make sure that they do not happen again
• Store data in safe and secure ways with limited access
• Assess the risk that could be posed to individual rights and freedoms should data be compromised at any time for any of the services we provide 

Your responsibilities – 

• Fully understand your data protection obligations within the business
• Check that any data processing activities you are dealing with comply with our policy and are justified with this
• Do not use data in any unlawful way towards any clients and other employees
• Do not store data incorrectly, be careless with it or otherwise cause us to breach data protection laws and our policies through your actions with the clients and Social Media Help
• Comply with this policy at all times when employed by Social Media Help.
• Raise any concerns, notify any breaches or errors, and report anything suspicious or contradictory to this policy or our legal obligations without delay to the person who you need to report to 

Responsibilities of the Data Protection Employee- 

• Keeping the relevant people updated about data protection responsibilities, risks and issues that arise
• Reviewing all data protection procedures and policies on a regular basis and make sure they are update
• Arranging data protection training and advice for all staff members and those included in this policy outline
• Answering questions on data protection from staff, members of Social Media Help and other stakeholders if applicable
• Responding to individuals such as clients and employees who wish to know which data is being held on them by Social Media Help
• Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing. To ensure that we are in complying with standards within the law and the business policies 

Responsibilities of the IT Manager – 

• Ensure all systems, services, software and equipment meet acceptable security standards of the UK/EU
• Checking and scanning security hardware and software regularly to ensure it is functioning properly within the business towards other businesses and clients
• Researching third-party services, such as cloud services the company is considering using to store or process data in them 

Responsibilities of the Marketing Managers – 

• Approving data protection statements attached to emails and other marketing copy. To make sure that it is correct
• Addressing data protection queries from clients, target audiences or media outlets
• Coordinating with Roché Beel to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy 

Accuracy and relevance – 

We will ensure that any personal data we process is accurate, relevant, and not unnecessary, given the purpose for which it was obtained.

We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this to happen from a known source.

Individuals may ask that we correct inaccurate personal data relating to them, by giving Social Media Help this in an email or over the phone.

If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform Roché Beel, to change this information if correct. 

Data security for Social Media Help – 

You must keep personal data secure against loss or misuse.

Where other organisations process personal data as a service on our behalf, Roché will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations used. 

Storing data securely – 

• In cases when data is stored on printed paper, it should be kept in a secure place where unauthorised personnel cannot access it. It must be in locked building in a locked place where it is stored
• Printed data should be shredded when it is no longer needed in the business premises or a known company that professionally shreds important confidential paper
• Data stored on a computer should be protected by strong passwords that are changed regularly. We encourage all staff to use a password manager to create and store their passwords on Google passwords.
• Data stored on CDs or memory sticks must be encrypted or password protected and locked away securely when they are not being used
• It must be approved when any data is of the cloud and used to store data
• Servers containing personal data must be kept in a secure location
• Data should be regularly backed up in line with the company’s backup procedures if any Data should never be saved directly to mobile devices such personal tablets or smartphones
• All servers containing sensitive data must be approved and protected by security software
• All possible technical measures must be put in place to keep data secure 

Individuals can exercise their rights in the following ways: 

1. Right to be informed – 

• Providing privacy notices which are concise, transparent, intelligible, and easily accessible to whoever needs this information, to be free of charge, and is written in clear and plain language.
• Keeping a record of how we use personal data to demonstrate compliance with the need for accountability and transparency.

2. Right of access – 

• Enabling individuals to access their personal data and supplementary information that they rightly can know
• Allowing individuals to be aware of and verify the lawfulness of the processing of activities

3. Right to rectification – 

• We must rectify or amend the personal data of the individual if requested because it is inaccurate or incomplete.
• This must be done without delay, and no later than one month of the request.

4. Right to erasure – 

• We must delete or remove an individual’s data if requested and there is no compelling reason for its continued processing for the business.

5. Right to restrict processing – 

• We must comply with any request to restrict, block, or otherwise suppress the processing of personal data with clients or employees.
• We are permitted to store personal data if it has been restricted, but not process it further. We must retain enough data to ensure the right to restriction is respected in the future.

6. Right to data portability – 

• We must provide individuals with their data so that they can reuse it for their own purposes or across different services that we provide to them.
• We must provide it in a commonly used, machine-readable format, and send it directly to another controller if requested by the same business.

7. Right to object – 

• We must respect the right of an individual to object to data processing based on legitimate interest or the performance of a public interest task.
• An of an individual to object to direct marketing, including profiling.
• We must respect the right of an individual to object to processing their data for scientific and historical research and statistics to help Social Media Help.

8. Rights in automated decision making and profiling –

• Individuals retain their right to object to such automated processing, have the rationale explained to them, and request human intervention. 

Privacy notices – 

When to supply a privacy notice 

A privacy notice must be supplied at the time the data is obtained if obtained directly from the data subject. 

If the data is not obtained directly from the data subject, the privacy notice must be provided within a reasonable period of having obtained the data, within one month of the request. 

The privacy notice must be supplied at the latest when the first communication takes place. 

If disclosure to another recipient is envisaged, then the privacy notice must be supplied prior to the data being disclosed. 

What to include in a privacy notice – 

Privacy notices must be concise, transparent, intelligible and easily accessible.

They are provided free of charge and must be written in clear and plain language. 

The following information must be included in a privacy notice to all data subjects: 

• Identification and contact information of the data controller and the data protection person.
• The purpose of processing the data and the lawful basis for doing so.
• The legitimate interests of the controller or third party, if applicable.
• The right to withdraw consent at any time, if applicable to the situation.
• The category of the personal data (only for data not obtained directly from the data subject at question)
• Any recipient or categories of recipients of the personal data needed to be collected.
• The retention period of the data, how long to keep this data and when to dispose of it. 
• The right to lodge a complaint with the and internal complaint procedures
• The source of the personal data, and whether it came from publicly available sources (only for data not obtained directly from the data subject)
• Any existence of automated decision making, how those decisions are made, their significances and consequences to the data subject held against them

Subject Access Requests – 

What is a subject access request?

An individual has the right to receive confirmation that their data is being processed, and access to their personal data information gathered by the company.

How we deal with any subject access requests –

We must provide an individual with a copy of the information the request, free of charge.

This must occur without delay, and within one month of receipt.

We need consent from the client or business unless they have requested it themselves.

Once consent is gathered we will then provide data subjects access to their information in electronic format on a PDF.

We can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee.

If the request is for a large quantity of data, we can request the individual specify the information they are requesting from Social Media Help.

Once a subject access request has been made, you must not change or amend any of the data that has been requested. Doing so is a criminal offence.

And Social Media Help will not be held responsible for any criminal offenses that this will cause.

The right to erasure –

Individuals have a right to have their data erased and for processing to cease in the following circumstances: 

• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected and / or processed within the business
• Where consent is withdrawn from Social Media Help
• Where the individual objects to processing and there is no overriding legitimate interest for continuing the processing this request
• The personal data was unlawfully processed or otherwise breached data protection laws within the UK
• To comply with a legal obligation
• The processing relates to a child under 18

How we deal with the right to erasure and can only refuse to comply with a right to erasure in the following circumstances – 

• To exercise the right of freedom of expression and this information
• To comply with a legal obligation for the performance of a public interest task or exercise of official authority requests this
• For public health purposes in the public interest
• For archiving purposes in the public interest, scientific research, historical research, or statistical purposes
• The exercise or defence of legal claims

 If personal data that needs to be erased has been passed onto other parties or recipients, they must be contacted and informed of their obligation to erase the data. If the individual asks, we must inform them of those recipients. 

The right to object – 

Individuals have the right to object to their data being used on grounds relating to their particular situation. 

We must cease processing unless: 

• We have legitimate grounds for processing which override the interests, rights and freedoms of the individual.
• The processing relates to the establishment, exercise or defence of legal claims.

Objection can be done online through email to info@socialmedia-help.co.uk

 The right to restrict automated profiling or decision making may only carry out automated profiling or decision making that has a legal or similarly significant effect on an individual in the following circumstances:

It is necessary for the entry into or performance of a contract.

• Based on the individual’s explicit consent.
• Otherwise authorised by law.

In these circumstances, we must:

• Give individuals detailed information about the automated processing.
• Offer simple ways for them to request human intervention or challenge any decision about them.
• Carry out regular checks and user testing to ensure our systems are working as intended.

Monitoring those working with or for Social Media Help – 

Everyone must observe this policy. 

Social Media Help Ltd will keep this policy under review and amend or change it as required. You must notify Roché of any breaches of this policy.

You must comply with this policy fully and at all times. 

Training – 

You will receive adequate training on provisions of data protection law specific for your role.

You must complete all training as requested.

If you move role or responsibilities, you are responsible for requesting new data protection training relevant to your new role or responsibilities. 

If you require additional training on data protection matters, contact Roché.

 Reporting breaches in Social Media Help –

 Any breach of this policy or of data protection laws must be reported as soon as practically possible. This means as soon as you have become aware of a breach. Social Media Help Ltd has a legal obligation to report any data breaches to [name of supervisory authority] within [72 hours of the breach].

All members of staff have an obligation to report actual or potential data protection compliance failures.

 This allows Social Media Help to:

 Investigate the failure and take remedial steps if necessary, within the business

• Maintain a register of compliance failures
• Notify the [name of supervisory authority] of any compliance failures that are material either or as part of a pattern of failures

 Any member of staff who fails to notify of a breach or is found to have known or suspected a breach has occurred but has not followed the correct reporting procedures will be liable to disciplinary action.

Which could result in a dismissal from Social Media Help.

 Failure to comply to this privacy policy –

 We take compliance with this policy very seriously. Failure to comply puts both you and the organisation at risk.

 The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in dismissal.

 If you have any questions or concerns about anything in this policy, do not hesitate to contact Roché.