Data Protection Policy

The Minerva Group needs to gather and use certain information about individuals and businesses. These can include clients, customers, suppliers, business contacts, employees and other people the organization 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 The Minerva Group:

• 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

Data protection law

The Colorado Protections for Consumer Data Privacy Act and The Gramm Leach Bliley Act (15 U.S. Code 6802(a) et seq.) describe how businesses in the State of Colorado and the U.S. — including The Minerva Group — must collect, handle and store Non-public Personal Information.

These laws establish key responsibilities for businesses that keep either paper or electronic documents containing personal identifying information:

1. Data must be obtained for specific, lawful purposes.
2. Businesses and agencies must have a written policy explaining how they will dispose of the personal information they keep and follow through on those procedures.
3. If a data breach is detected, entities must alert consumers that their data has been compromised within 30 days. If more than 500 individuals are impacted, the entity must alert the attorney general’s office.
4. Entities must take “reasonable” steps to protect the personal information they keep.

People, risks and responsibilities

This policy applies to:

• The primary office and any branches of The Minerva Group
• All staff and volunteers of The Minerva Group
• All contractors, suppliers and other people working on behalf of The Minerva Group

It applies to all data that the company holds relating to identifiable individuals and businesses, even if that information technically falls outside of the Colorado Protections for Consumer Data Privacy Act or The Gramm Leach Bliley Act. This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Social Security numbers
• Financial institution information (including account numbers and online logins)
• Federal and State Identification numbers

Data protection risks

This policy helps to protect The Minerva Group 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 The Minerva Group has some responsibility for ensuring data is collected, stored and handled appropriately.

However, the Operations Manager and CEO continually review current data protection policies and internal procedures to ensure the security of personal information; including:

• 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 uses or is considering using to store or process data; verifying that they meet or exceed the standards in this data policy.

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 the Operations Manager.
• The Minerva Group 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 unauthorized 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.
  • Avoid opening attachments and clicking on links in emails from unknown or suspicious senders.
  • Report stolen or damaged equipment as soon as possible to the Operations Manager and change all account passwords at once when a device is stolen.
  • Report a perceived threat or possible security weakness in company systems.
  • Refrain from downloading suspicious, unauthorized or illegal software on their company equipment.
  • Avoid accessing suspicious websites.
  • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
  • Employees should request help from the Operations Manager if they are unsure about any aspect of data protection.

Data storage                                                                                                                     

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Operations Manager.

When data is stored on paper, it should be kept in a secure place where unauthorized 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 in use, 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 unauthorized 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 unauthorized 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.
• All servers and computers containing data should be protected by approved security software (Anti-Virus and Anti-Malware) and a firewall.

Data use                                                                                                                             

Personal data is of no value to The Minerva Group 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:

• 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 Operations Manager can explain how to send data to authorized external contacts.
• Always access and update the central copy of any data.

Data accuracy

The law requires The Minerva Group 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 The Minerva Group 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.
• The Minerva Group will make it easy for data subjects to update the information The Minerva Group 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.

Information Requests                                                                                               

All individuals who are the subject of personal data held by The Minerva Group 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.

Information requests from individuals or business should be made by email, addressed to our Chief Operations Officer at joseph@theminervagroup.com.

The Chief Operations Officer will always verify the identity of anyone making an information request before handing over any information.

Disclosing data for other reasons                                                                

In certain circumstances, personal data may be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, The Minerva Group will disclose requested data. However, the Operations Manager will ensure the request is legitimate, seeking assistance from the CEO and from the company’s legal advisers where necessary.