Context and overview

Introduction

Ambassify needs to gather and use certain information about individuals. 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 law.

Why this policy exists

This data protection policy ensures Ambassify:

  • 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

People, risks and responsibilities

Policy scope

This policy applies to:

  • The head office of Ambassify
  • All branches of Ambassify
  • All staff and volunteers of Ambassify
  • All contractors, suppliers and other people working on behalf of Ambassify

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. 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 Ambassify 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

Everyone who works for or with Ambassify has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team 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 board of directors is ultimately responsible for ensuring that Ambassify meets its legal obligations.
  • The Security Officer, Wim Mostmans, 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 Ambassify 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.
    • 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.
    • 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.
  • Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
  • Ambassify 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.
  • In particular, strong passwords must be used and they should never be shared.
  • 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. 
  • We apply a clear desk and clear screen policy (CDCS)

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 should be protected by strong passwords that are changed regularly and never shared between employees.
  • 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 services.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to Ambassify 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. In particular, it should never be sent by email, as this form of communication is not secure.
  • Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
  • Personal data should never be transferred outside of the European Economic Area.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy

The law requires Ambassify to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort Ambassify 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. 

  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
  • Ambassify will make it easy for data subjects to update the information Ambassify holds about them. For instance, via the company website.
  • 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.

Data encryption

In Transit

Data in transit is any type of information that is transmitted between systems, applications or locations. Encryption of data in transit is a critical mechanism to protect that data. Unauthorized disclosure or alterations of data in transit could cause perceivable damage.

Ambassify uses industry-accepted encryption products to protect Customer Data and communications during transmissions between a Customer’s network and Ambassify, including 256-bit Elliptic Curve and 2048-bit RSA TLS Certificates and 2048-bit RSA public keys at a minimum. Encryption keys and secrets are safeguarded in a secure data vault that is restricted to authorized users and applications as defined in our access control policy.

Communication between internal Ambassify services such as databases, storage and individual servers is protected using transport-level encryption to protect data in transit in order to ensure delivery without eavesdropping, interception or forgery.

TLS Certificates used by Ambassify are either signed and managed by Cloudflare Inc., Amazon or Let’s Encrypt (as part of Heroku SSL) and issuance is monitored using Certificate Transparency Monitoring by Facebook.

Customer information electronically transfered must be enclosed in a file and encrypted using a product approved by the Information Security policy set at an appropriate strength. Minimum standard for encryption is AES (256 bit).

  • Any password must be to Ambassify standard. Details of the password policy can be found in the Information Security policy.
  • Any password to open the attached file must be transferred to the recipient using a different method than e-mail, e.g. a telephone call to an agreed telephone number, closed letter.
  • An accompanying message should contain clear instructions on the recipient’s responsibilities, and instructions on what to do if they are not the correct recipient.
  • An accompanying message and the filename must not reveal the contents of the encrypted file.

At Rest

Data at rest is a phrase that is used to refer to all data on a physical storage device that does not move, excluding information traversing a network or temporarily residing in computer memory. Data at rest can reside in static files that rarely or never change or can be subject to regular change.

Customer data and backups of customer data should always be encrypted with at least AES-256 encryption before being written to any permanent medium such as HDDs or SSDs.

Third Parties

Ambassify uses some third-party services to host parts of the infrastructure that runs the platform. The table below describes the different levels of encryption offered and in use by Ambassify.

Third-Party Encryption at rest Encryption of backups Encryption in-transit  
Graph Story AES-256 AES-256 128-bit SSL *
Amazon AWS S3 AES-256 AES-256 2048-bit RSA TLS  
Amazon AWS RDS AES-256 AES-256 2048-bit RSA TLS *
RedisLabs No AES-256 SSL/TLS *

Vurnability Management

Because our servers are managed by our hosting providers Heroku and Amazon Web Services, our patch managent on a OS and software level is inherited from these companies.

For our own application code we have automated processes in place that are part of our change management to check for usage of potential insecure dependencies. Existing code is also constantly monitored using software to automatically detect vurnable dependencies.

Subject access requests

All individuals who are the subject of personal data held by Ambassify 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 [email address]. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged €20 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, Ambassify 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.

Affected clients will be notified via e-mail about inquiries.

Providing information

Ambassify 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 statement, setting out how data relating to individuals is used by the company.