Definitions and interpretation
|Data||collectively all information that you submit to Segbo Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;|
|Cookies||a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);|
|Data Protection Laws||any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;|
|GDPR||the General Data Protection Regulation (EU) 2016/679;|
|Segbo Limited, or us||Segbo Limited, a company incorporated in England and Wales with registered number 60 whose registered office is at Dudley Road East, Oldbury, West Midlands, B69 3HJ;|
|UK and EU Cookie Law||the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronxic Communications (EC Directive) (Amendment) Regulations 2011;|
|User or you||any third party that accesses the Website and is not either (i) employed by Segbo Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Segbo Limited and accessing the Website in connection with the provision of such services; and|
|Website||the website that you are currently using, www.segbo.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.|
- the singular includes the plural and vice versa;
- a reference to a person includes firms, companies, government entities, trusts and partnerships;
- “including” is understood to mean “including without limitation”;
- reference to any statutory provision includes any modification or amendment of it;
- For purposes of the applicable Data Protection Laws, Segbo Limited is the “data controller”. This means that Segbo Limited determines the purposes for which, and the manner in which, your Data is processed.
- We may collect the following Data, which includes personal Data, from you:
- date of birth;
- contact Information such as email addresses and telephone numbers;
- demographic information such as postcode, preferences and interests;
- financial information such as credit / debit card numbers;
- IP address (automatically collected);
- web browser type and version (automatically collected);
- operating system (automatically collected);
- a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
How we collect Data
- We collect Data in the following ways:
- data is given to us by you; and
- data is collected automatically.
Data that is given to us by you
- Segbo Limited will collect your Data in a number of ways, for example:
- when you contact us through the Website, by telephone, post, e-mail or through any other means;
- when you register with us and set up an account to receive our products/services;
- when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
- when you enter a competition or promotion through a social media channel;
- when you make payments to us, through this Website or otherwise;
- when you elect to receive marketing communications from us;
- when you use our services;
Data that is collected automatically
- To the extent that you access the Website, we will collect your Data automatically, for example:
- we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
- we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.
Our use of Data
- Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
- internal record keeping;
- improvement of our products / services;
- transmission by email of marketing materials that may be of interest to you;
- contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
- process orders;
- We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
- For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
- soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
- for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
- if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
- When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Who we share Data with
- We may share your Data with the following groups of people for the following reasons:
- any of our group companies or affiliates – to ensure the proper administration of your website and business;
- our employees, agents and/or professional advisors – to process orders and make contact with third party courier services;
- third party service providers who provide services to us which require the processing of personal data – to help third party service providers in receipt of any shared data to perform functions on our behalf to help ensure the website runs smoothly;
- third party payment providers who process payments made over the Website – to enable third party payment providers to process user payments and refunds;
- relevant authorities – upon request by the government authorities we are obliged under the law to share your information;
Keeping Data secure
- We will use technical and organisational measures to safeguard your Data, for example:
- access to your account is controlled by a password and a user name that is unique to you.
- we store your Data on secure servers.
- payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.
- We are certified to SOC 2. This family of standards helps us manage your Data and keep it secure.
- Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: [email protected].
- If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
- Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
- You have the following rights in relation to your Data:
- Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
- Right to erase – the right to request that we delete or remove your Data from our systems.
- Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
- Right to data portability – the right to request that we move, copy or transfer your Data.
- Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
- To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: [email protected]
- If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
- It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to other websites
Changes of business ownership and control
- We may also disclose Data to a prospective purchaser of our business or any part of it.
- In the above instances, we will take steps with the aim of ensuring your privacy is protected.
- All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
- Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Segbo Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
- This Website may place the following Cookies:
|Type of Cookie||Purpose|
|Strictly necessary cookies||These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.|
- You can find a list of Cookies that we use in the Cookies Schedule.
- You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
- You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
- It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
- For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
- Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
- This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
23 May 2018
Data Breach Reporting Procedure
As a company we hold, process and share personal data for retail purposes. Every care is taken to protect this personal information from accidental or deliberate misuse, to avoid a data breach that could compromise security and confidentiality.
However, as the amount of data available grows and technology develops, there are new ways by which data can be breached. Segbo Limited needs to have in place a robust and systematic process for responding to any reported data breaches, to ensure it can act legally and responsibly, and protect personal data which it processes.
The aim of this procedure is to standardise the Company’s response to any data breach and ensure that they are appropriately logged and managed in accordance with the law and best practice, so that:
- incidents are reported swiftly and can be properly investigated
- incidents are dealt with in a timely manner and normal operations restored
- incidents are recorded and documented
- the impact of the incident is understood, and action is taken to prevent further damage
- the ICO and data subjects are informed as required in more serious cases
- incidents are reviewed, and lessons learned
Data breaches and ‘near misses’
What is a data breach?
Article 4 (12) of the General data protection Regulation (“GDPR”) defines a data breach as: “a breach of security leading to the unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.”
It is important to note that a potential data breach does not always involve technical systems or IT devices. Breaches can also involve paper-based and verbal information, for example a diary with personal details left in a coffee shop, or inappropriate disclosure of someone’s information through conversation.
Segbo Limited is obliged under the GDPR to act in respect of such data breaches. This procedure sets out how the Company will manage a report of a suspected data breach. The aim is to ensure that where data is misdirected, lost, hacked or stolen, inappropriately accessed or damaged, the incident is properly investigated and reported, and any necessary action is taken to rectify the situation.
A data breach can come in many forms, but the most common are as follows:
- Loss or theft of paper or other hard copy
- Human error – e-mailed, posted or faxed to the incorrect recipient
- Loss or theft of equipment on which data is stored
- inappropriate sharing or dissemination and/or inappropriate access controls – staff accessing information to which they are not entitled
- Hacking, malware and data corruption
- Information is obtained by deception or “blagging”
- Equipment failure, fire or flood
- Unescorted visitors accessing data
- Non-secure disposal of data What is a near miss?
A ‘near miss’ can be described as an unplanned event that did not lead to a data breach but had the potential to. It can also be described as a ‘data incident’ which requires some investigation to identify whether an actual breach has occurred: the initial investigation may change the status from incident to breach and invoke the full breach investigation procedure.
Near misses should be reported in the same way as breaches, using the procedures below. Once further information is gathered it will be determined whether an incident was a ‘near miss’ or is escalated as an actual breach.
In any situation where staff are uncertain whether an incident constitutes a full data breach or might be a ‘near miss’ it should be reported anyway using the procedures below. It is better to report something that can be acknowledged and that we can learn from than not report something that then escalates into a major issue.
National Deals LTD policy applies to all Company’s information, regardless of format, and is applicable to all staff, contractors, partner organisations and data
processors acting on behalf of the Company. It is to be read in conjunction with the Company Data Policy, which is available on our website.
All staff have a responsibility for reporting suspected or actual data breaches as soon as possible. Staff are also responsible for assisting with investigations as required, particularly if urgent action must be taken to prevent further damage.
The Leadership Team members are responsible for ensuring that staff in their area comply with this policy and assist with investigations as required.
Data Protection Officer and Managing Director at Segbo Limited
Both will be responsible for ensuring any reported breach is investigated, following these procedures. Suitable further delegation may be appropriate in some circumstances.
Information Security Lead
Responsible, along with the DPO and MD at ND Ltd, for ensuring reported security breaches are investigated, following these procedures, and that appropriate remedial action is taken, where required. Suitable further delegation may be appropriate in some circumstances.
- Reporting a breach – internal reporting
Suspected data breaches should be reported promptly to the DPO as the primary point of contact: [email protected] The report must contain full and accurate details of the incident including who is reporting the incident and what kind of data is involved. The incident report form should be completed as part of the reporting process (Appendix 1).
If a breach occurs or is discovered outside normal working hours it must be reported as soon as is practicable, taking into account the potential severity of the incident.
Once a data incident has been reported an initial assessment will be made to establish whether it is a breach, and the severity of the breach (see Appendix 2 – matrix for assessing severity of incident). All data breaches will be centrally logged by the DPO to ensure appropriate oversight in the types and frequency of confirmed incidents for management and reporting purposes.
Invigilation of assessment is carried out by a designated person where this is necessary to meet specified assessment conditions.
- Reporting a breach – external reporting
Article 33 of the GDPR requires the Company to notify the ICO only when the breach “is likely to result in a risk to the freedoms and rights of natural persons”. Such a breach also must be communicated to the data subject (with certain exceptions).
Notification must be made “without undue delay” and within 72 hours of becoming aware of it. If the College fails to do this, it must explain the reason for the delay.
A report to the ICO will be made by the DPO and must contain information as to the nature of the breach, categories of data, number of data records, number of people affected, name and contact details of DPO, likely consequences of the breach and action taken.
- Containment and recovery
The DPO and Info Sec Lead will identify who should lead on investigating and managing the breach.
- The DPO and Info Sec Lead will determine whether the breach is still occurring and if so, ensure appropriate steps are taken immediately to identify and implement any steps to contain the breach and minimise the
- An initial assessment will be made, with relevant staff, to establish the severity of the breach.
- The DPO and Info Sec Lead will establish whether anything can be done to recover any losses and limit damage
- The DPO and Info Sec Lead will establish who may need to be notified as part of the initial containment
- The DPO and Info Sec Lead, in liaison with relevant staff, will determine a suitable course of action to ensure resolution of the incident
- The DPO and Info Sec Lead should consider whether the Director of Marketing and Communications should be informed at this stage, to prepare external or internal communications and be ready to handle enquiries.
- Assessment of risks
- An investigation will be undertaken by the DPO or Info Sec Lead immediately and whenever possible within 24 hours of the breach being discovered/reported.
- All data security breaches will be managed according to risk. After the identification of the breach, the risks associated with the breach will be assessed in order to identify an appropriate response. Appendix 1 should be used to identify the exact nature of the breach and the severity; this information can then be used to establish the action
- The investigation will take into account:
- the type of data involved and its sensitivity
- the protections which are in place (e.g. encryption)
- what’s happened to the data, has it been lost or stolen
- whether the data could be put to any illegal or inappropriate use
- who the individuals are, number of individuals involved and the potential effects on those data subject(s)
- whether there are wider consequences to the breach
- Consideration of further notification
- The DPO and Company’s Managing Director will access and Partnerships, determine who needs to be notified of the
- Ultimately, the DPO will decide whether the ICO should be notified of the breach within the required 72 hours
- Use of the severity matrix will help determine the risk to people’s rights and freedoms and will aid the decision to notify the ICO (and the data subject(s)).
- Every incident will be assessed on a case by case basis, considering:
- Whether there are any legal/contractual notification requirements
- Whether notification would assist the individual affected – could they act on the information to mitigate risks?
- Whether notification would help prevent the unauthorised or unlawful use of personal data?
- Would notification help the Company meet its obligations under the seventh data protection principle?
- The dangers of over Not every incident warrants notification and over notification may cause disproportionate enquiries and work.
- The DPO and/or Company Managing Director will also consider notifying third parties such as the police, insurers and trade This would be appropriate where illegal activity is known or believed to have occurred, or there is a risk of illegal activity happening in the future.
- Notification to the individual(s) whose personal data has been affected by the incident will include a factual description of how and when the
breach occurred and the data involved, along with actions taken by the Company. Individuals will also be provided with the name and contact details of the Company DPO for further information.
- All decisions and actions will be documented by the
- Evaluation and response
- Once the initial incident is contained, the DPO and/or Info Sec Lead will carry out a full review of the causes of the breach, the effectiveness of the response and determine whether any changes to systems, policies or procedures should be made
- The review will consider:
- Where and how personal data is held and where and how it is stored
- Where the biggest risks lie, and will identify any further potential weak points within its existing measures
- Whether methods of transmission are secure; sharing minimum amount of data necessary
- Identifying weak points within existing security measures
- Staff awareness
- Implementing a data breach plan and identifying a group of individuals responsible for reacting to reported breaches
- If deemed necessary a report recommending any changes to systems, policies and procedures will be considered by Company’s Senior Management Team and in more serious cases it may be appropriate to report to the Company Board or appropriate
Throughout the breach management process a record should be kept of actions taken and by whom. An activity log recording the timeline of the incident management will also be completed. Appendix 4 provides an activity log template to record this information. Copies of any correspondence relating to the breach should also be retained.
- Breaches received as complaints
There are occasions when a data subject may make the company aware of a data breach by using the company’s complaints procedure. If this is the case, the Managing Director will forward the complaint to the Data Protection Officer to be dealt with as a data breach.
The complainant will receive acknowledgement from the Company informing them that this will be handled in line with the Company’s Breach Reporting Procedure.
The [email protected] inbox will be copied into all communications with the complainant. The complaint will be sent to the DPO and this will not be counted in the complaint reporting process.
Staff, contractors, visitors or partner organisations who act in breach of company’s policy and procedure may be subject to disciplinary procedures or other appropriate sanctions.
Data Protection Officer: [email protected]ationaldeals.co.uk
Date of Version: Responsibility for Procedure:
Approved for Use
Director of Segbo Limited
Responsibility for Implementation: Director of Segbo Limited
Responsibility for Review: Director of Segbo Limited
Date of EIA: Review Date:
APPENDIX A – DATA INCIDENT REPORTING FORM
Sections 1 and 2 must be completed as part of the initial report.
Please complete those sections as soon as possible and email it to the Data Protection Officer: [email protected] without delay. The
Circulation of this form and any related documents must be restricted to those directly involved in the investigation.
Do not refer to any data subjects by name in this report.
|Section 1||Details of person reporting the incident|
|Date of report|
|Section 2||Details of the incident|
|Date and time |
incident was discovered
|Brief description of event and circumstances – time, date, location, how it occurred, etc|
|Has there been any delay in reporting this? |
If yes, please explain the reason(s)
|Yes / No|
|Did the incident involve personal data? |
If no, submit the form now
If yes, complete the rest of this section
|Yes / No|
|Describe the type of personal data compromised. Give as much detail |
|Was any sensitive data compromised? (eg health info, race, ethnic origin, religious or political |
|Yes / No|
|Described the type of sensitive personal data compromised. Give |
as much detail as possible
|Is the breach contained or |
|Yes / No|
|What steps were/will be taken to |
contain the breach?
|When was the breach contained?|
|If data is lost or stolen, what steps are being taken to recover the data? If recovered, what steps were |
|Section 3||Personal data compromised|
|Number of individuals whose personal data has been |
|Types of individual(s) whose data has been compromised – student, staff, job applicant, alumni, children, |
|Are the affected individuals aware |
of the incident?
|Yes / No|
|Have any of the individuals affected |
complained about the incident?
|Yes / No|
|Section 4||Containment and recovery|
|Details of any measures in place to prevent an incident like this occurring eg encryption, back-up, |
|Details of any 3rd party service providers involved in the breach|
|Please provide extracts or links to any policies and/or procedures that are relevant to |
this incident eg information security
|Section 5||Assessment of risks|
|Is the information unique? Can it be restored or is it lost completely? Will its loss have an adverse effect on college |
|Is the data bound by any contractual security arrangements? Inc. a data sharing |
|Section 6||Further notification|
|Have the Vice Principal – Access and Partnerships and Principal |
|Does the ICO require to be |
|Does the data subject(s) require to |
|Do the Police or other regulatory |
authority need to be informed?
|Section 7||Evaluation and response|
|Description of action taken in response to the incident|
|Has the person(s) responsible for or |
involved in the incident undertaken data protection
|training? If yes please state what and |
|What steps/actions can be taken to minimise the possibility of a repeat |
of such an incident?
|Section 8||Overall assessment|
|Incident severity (using severity matrix) |
Breakdown calculation of score
|Overall assessment – likely to result in: |
A – no risk to the data subject B – risk to the data subject
C – high risk to the data subject
Provide explanation for decision
APPENDIX B – MATRIX FOR ASSESSING SEVERITY OF INCIDENT
Data subjects affected
|Description||Scenario||Code letter||Risk rating|
|High||500 – 999||H||4|
|Medium||100 – 499||M||3|
|Low||10 – 100||L||2|
|Very low||0 – 10||VL||1|
|Description||Score||Code letter||Risk rating|
|Very high||Individuals may encounter significant, or even irreversible, consequences, which they may not overcome (financial distress such as substantial |
debt or inability to work, long-term psychological or physical ailments, death, etc.).
|High||Individuals may encounter significant consequences, which they should be able to overcome albeit with serious difficulties (misappropriation of funds, blacklisting by banks, property damage, loss of employment, subpoena, |
worsening of health, etc.).
|Medium||Individuals may encounter significant inconveniences, which they will be able to overcome despite a few difficulties (extra costs, denial of access to business services, fear, lack of |
understanding, stress, minor physical ailments, etc.).
|Low||Individuals may encounter a few inconveniences, which they will overcome without any problem (time spent re-entering information, annoyances, irritations, etc.)||L||2|
|Very low||No evidence that individuals will be materially |
Score = Data subjects affected x impact score
|Description||Score||Notify ICO||Notify data subjects|
|High||16 – 19||Yes||Yes|
|Medium||11 – 15||Consider||Yes|
|Low||6 – 10||No||Consider|
|Very low||1 – 5||No||No|
A final decision about notification to ICO, and whether to inform the data subjects will be made by the DPO.
APPENDIX C – DATA BREACH FLOWCHART
APPENDIX 4 – ACTIVITY LOG
|Date / Time||Activity |
Activity, Decision, Instruction, Briefing ( A,D,I,B )
Equality Impact Assessment (EIA) Form
Part 1. Background Information. (Please enter relevant information as specified.)
|Title of Policy or Procedure. Details of Relevant Practice:||Procedure 1095: Data Breach Reporting Procedure|
|Person(s) Responsible.||Managing Director at Segbo Limited|
|Date of Assessment:||03/03/2020|
|What are the aims of the policy, procedure or practice being |
|Leave blank if these are already explicit on the existing paperwork.|
|Who will this policy, procedure or practice impact |
|All staff who work at Segbo Limited.|
Part 2. Public Sector Equality Duty comparison (Consider the proposed action against each element of the PSED and describe potential impact, which may be positive, neutral or negative. Provide details of evidence.)
|· Eliminating unlawful discrimination, harassment and victimisation||This procedure ensures all staff members are treated equally regardless of any protected characteristics that may apply. |
|Regulatory body guidance and codes of practice were consulted.|
|· Advancing Equality of Opportunity||The procedure ensures that the personal data is protected for all and that any breaches are dealt with in an equitable manner for all data subjects. |
|Inherent to data breach reporting procedure is the requirement to protect the rights and freedoms of all data subjects.|
|· Promoting Good relations||Providing a consistent and equitable process promotes good relations for all data |
|An identified process should provide assurance of appropriate handling to all data subjects.|
Part 3. Action & Outcome (Following initial assessment, describe any action that will be taken to address impact detected)
|Sign-off, authorisation and publishing *|
|Name:||Muhammad Jawad Siddiqui|