Data Protection Policy
Upstream IT Limited shall be called “the company”.
The company needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, 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 that the company complies with data protection legislation including the Data Protection Act and the General Data Protection Regulations (GDPR).
Data protection law
The GDPR describes how organisations — including the company — must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
People, risks and responsibilities
This policy applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR.
Data protection risks
This policy helps to protect the company from some very real data security risks, including: Hacking, phishing, accidental disclosure, etc.
Everyone who works for or with the company has some responsibility for ensuring data is collected, stored and handled appropriately. Whomever at the company 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:
Steven Cowan (who shall be called “the data protection officer”) is ultimately responsible for ensuring that the company meets its legal obligations.
The data protection officer is responsible for IT used at the company, including computers, laptops, mobile phones and other devices that can store personal data.
The data protection officer is responsible for any marketing related activities at the company.
General guidelines for data usage
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 or access 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. The data protection officer will 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.
Personal data is of no value to the company 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.
The law requires the company 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 company should put into ensuring its accuracy. The data protection officer is 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. The data protection officer should not create any unnecessary additional data sets. The data protection officer should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call. The company will make it easy for data subjects to update the information the company 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 data protection officer’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject access requests
All individuals who are the subject of personal data held by the company are entitled to request a copy of any personal data the company holds about them.
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 to firstname.lastname@example.org . You can also call the company directly at 0131 513 9971.
There is no charge for subject access request. The company will aim to provide the relevant data within 30 days.
The company 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 GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, the company 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.
The company aims to ensure that individuals are aware that their data is being processed, and that they understand how their data is being processed and for what reasons.
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.
Upstream IT Limited shall be called “the company”.
Use of this website | Terms and conditions
This Website is controlled and operated by Upstream IT Limited, 1 Rutland Sqaure, Edinburgh, EH1 2AS, registered No. SC311050 in Scotland, United Kingdom. The company make no representation that materials in the website are appropriate or available for use in other locations. Anyone who elects to access this website from any other location does so on their own initiative and is responsible for compliance with applicable local laws.
Use of website
The terms and conditions apply to your use of the company’s website at www.upstreamit.co.uk (the “website”). The terms and conditions apply regardless of how you access the website, including any devices by which you can access the website at home, or on the move. You must read these Terms and Conditions carefully, and we recommend that you print and keep a copy for your future reference. By accessing, browsing, using the website or sending me information through the website, you confirm that you have read, understood and agree to these terms and conditions in their entirety. If you do not agree to these terms and conditions in their entirety, please do not use this website.
The copyright in all material provided on this website is held by the company or the photographer who have kindly allowed us to use their images on our website. Except as advised herein, none of the material on this site may be copied, reproduced, distributed, republished, downloaded, displayed, posted or transmitted in any form or by any means, including, but not limited to, electronic, mechanical, photocopying, recording, or otherwise, without the prior written permission of the company.
Any use of these materials on any other site or networked computer environment for any purpose is prohibited.
Permission is granted to display and download the materials for your personal, non-commercial use only, provided you do not modify the materials and that you retain all copyright claims, marks and other proprietary notices contained within the materials. You can share the link to this website’s homepage or individual pages or blog post on social media.
Ownership rights / copyright
All rights, including copyright and other intellectual property rights, in and to this website are owned by or licensed to the company.
Links to external websites
Links to third party websites on this site are provided solely as a convenience to you. If you use these links, you will leave the company’s website. The company do not actively review all of these third party sites, nor do they possess any control and are not responsible for any of these sites or their content.
Thus, the company does not endorse or make any representations about any other linked site, or any information, software or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third party sites linked from this Site, you do this entirely at your own risk.
Personal information that this website collects and why we collect it
This website collects and uses personal information for the following reasons:
Website visitor tracking
Like most websites, this website uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our website, so we can better understand how they find and use our web pages and see their journey through our website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. For this reason, we have also enabled IP address anonymisation so that our website users’ IP addresses are not transmitted to Google. You can read about this here.
If you wish, you may disable cookies in your internet browser. This will stop GA from tracking any part of your visit to pages within this website.
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor (see below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the MailChimp database, you may receive periodic newsletter-style emails from us.
Buying digital products from us
When you buy a digital product through our website, the details you submit are stored on our web server in our web database, as well as our internal computers. Once the order is completed, we aim to remove the details from our web database within one year of purchasing products online. The reason why we keep the data for one year is that you might consider purchasing additional products from us. In this case, you do not need to re-enter all your details. You can also request that we remove all your details from our database.
Contact forms and email links
Should you choose to contact us using one of the contact form on our website, or email us directly, none of the information / data that you supply will be stored by this website or passed to / be processed by any of the third party data processors (see below). Instead the data will be sent to us using the Simple Mail Transfer Protocol (SMTP). Our own SMTP servers are protected by TLS(sometimes known as SSL) meaning that the email content is encrypted before being sent across the internet. The email content is then decrypted by our local computers and devices. However, not all mail servers are secured in such a way. Therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.
Access to your personal information
If you are a client, or have enquired about our services, we will keep some personal data on file. You are entitled to view, amend, or request the personal information that we hold to be deleted. Email your request to the data protection officer.
About this website’s server
This website is hosted by Cloud Access within a EU data centre.
Full details of Cloud Access Security can be found here: https://www.cloudaccess.net/privacy-policy.html
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
Our third party data processors
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen.
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
The data controller of this website is:
Upstream IT Limited
1 Rutland Square
Edinburgh, EH1 2AS
Tel: 0131 513 9971
Data protection officer
Upstream IT Limited
1 Rutland Square
Edinburgh, EH1 2AS
Tel: 0131 513 9971