Last updated 19th April 2019
|Company||means ‘Financial Crime Services Ltd’|
|GDPR||means the General Data Protection Regulation.|
|Responsible Person||means Jerry Walters|
|Register of Systems||means a register of all systems or contexts in which personal data is processed by the company.|
1. Data protection principles
The Company is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General provisions
a. This policy applies to all personal data processed by the Company.
b. The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.
d. The Company shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to the company shall be dealt with in a timely manner.
4. Lawful purposes
a. All data processed by the company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
b. The lawful basis for the company processing data is to allow regulated firms who are clients of the company to undertake Customer Due Diligence and therefore comply fully with its legal obligations in relation to the legislation namely the Money Laundering, Terrorist Financing and Transfer of Funds (information on the Payer) Regulation 2017.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.
5. Data minimisation
a. The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
a. The Company shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
7. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.
c. At the date of drafting this Policy any record or personal data accumulated as a result of undertaking the CDD process on behalf of a third party shall be destroyed within 7 days of providing the third party with the information.
a. The Company shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.
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www.financialcrimeservices.com. It is stored on your hard drive. There are several types of cookie that are used to keep track of information needed by a site user as they travel from page to page within a website.
Other types of cookie can be used to track internet activity after the user has left a website. These are normally facilitated by organisations external to the website being visited and are generally known as ‘third party’ cookies. These usually have a long lifetime with several months being quite common. They are “harvested” and “refreshed” whenever the user visits a page where the same or a similar cookie is being used.
You can review the options available to manage cookies in your browser and you may revoke your consent at any time via the options available in your browser. Internet browsers normally accept cookies by default, but it is possible to set a browser to reject cookies. If this is done it is important not to exclude the benign and useful cookies. Choose an option that rejects all third party and long-lived cookies. Different browsers use different ways to disable cookies, but they are usually found under a Tools or Options menu. You can also consult the browser’s help menu.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
END OF POLICY