DATA PROTECTION POLICY

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1 Policy brief & purpose

a. Kaaizen HR Services Data Protection Policy refers to our commitment to treat information of employees, customers, stakeholders and other interested parties with the utmost care and confidentiality. With this policy, we ensure that we gather, store and handle data fairly, transparently and with respect towards individual rights

Who is covered under the Data Protection Policy?

Employees of Kaaizen HR Services and its subsidiaries must follow this policy. Consultants, partners and any other external entity are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf and may need occasional access to data.

2 Data Protection Principles

The Kaaizen HR Services is committed to processing data in accordance with its responsibilities.

Data Protection 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.”

3 General provisions

a. This policy applies to all personal data processed by the Kaaizen HR Services.

b. The Responsible Person shall take responsibility for the Kaaizen HR Services ongoing compliance with this policy.

c. This policy will be reviewed annually.

4 Data minimisation

a. The Kaaizen HR Services shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

5 Accuracy

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. 

5 Archiving / Removal

a. To ensure that personal data is kept for no longer than necessary, Kaaizen HR Services has archiving policy for each area in which personal data is processed and review the process annually.

b. The archiving policy shall consider what data should/must be retained.

6 Security

a. The Kaaizen HR Services shall ensure that personal data is stored securely. 

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.

7 Breach

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, Kaaizen HR Services shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach for disciplinary actions.