Policy brief & purpose

Our Data Protection company 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. We collect, gather, and store data to meet the company’s data protection standards and to comply with the law.

This data protection policy ensures Conexus SG, LLC:

• Complies with data protection law and follows 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
  
  

Conexus SG, LLC is committed to ensuring that all information handled by us will be processed accordingly to legally compliant standards of data protection and data security.

The purpose of this policy is to help us achieve our data protection and security aims by:

1. Notifying our staff, customers, and partners of the types of personal and financial information that we may hold on them and what we do with that information;
   1. Ensuring staff understand our rules and the legal standards for handling personal and financial information relating to staff and customers; and
   1. Clarifying the responsibilities and duties of staff in respect of data protection and data security.

Scope

This policy refers to all parties (employees, job candidates, customers, contractors, suppliers, etc.) who provide any amount of information to us.

Employees of our company and its subsidiaries must follow this policy. Contractors, 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.

This policy applies to all employees in all departments of Conexus SG, LLC, no exceptions.

This policy pertains to all external cloud services, e.g. cloud-based email, document storage, Software-as-a-Service (SaaS), Infrastructure-as-a-Service (IaaS), Platform-as-a-Service (PaaS), etc.

Definition of data to be protected includes, but is not limited to the following:

• Financial
• Restricted/Sensitive
• Confidential
• IP
• Names of individuals
• Personal Contact information
• Plus, any other information relating to individuals

Policy elements

As part of our operations, we need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, usernames and passwords, digital footprints, financial data, etc.

Our company collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply.

Our data will be:

• Accurate and kept up-to-date
• Collected fairly and for lawful purposes only
• Processed by the company within its legal and moral boundaries
• Protected against any unauthorized or illegal access by internal or external parties

Our data will not be:

• Communicated informally
• Stored for more than a specified amount of time
• Transferred to organizations, states or countries that do not have adequate data protection policies
• Distributed to any party other than the ones agreed upon by the data’s owner (exempting legitimate requests from law enforcement authorities)
• In addition to ways of handling the data the company has direct obligations towards people to whom the data belongs.

Specifically, we must:

• Let people know which of their data is collected
• Inform people about how we’ll process their data
• Inform people about who has access to their information
• Have provisions in cases of lost, corrupted or compromised data
• Allow people to request that we modify, erase, reduce or correct data contained in our databases
  
  

Actions

To exercise data protection, we’re committed to:

• Restrict and monitor access to sensitive data
• Develop transparent data collection procedures
• Train employees in online privacy and security measures
• Build secure networks to protect online data from cyberattacks
• Establish clear procedures for reporting privacy breaches or data misuse
• Include contract clauses or communicate statements on how we handle data
• Establish data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorization, etc.)
  
  

Data Security

1. We must all protect personal and financial information in our possession from being accessed, lost, deleted, or damaged unlawfully or without proper authorization through the use of data security measures.
2. Maintaining data security means making sure that:
   1. Only people who are authorized to use the information can access it;
   1. Information is accurate and suitable for the purpose for which it is processed; and
   1. Authorized persons can access information if they need it for authorized purposes. Personal and financial information therefore should not be stored on individual computers but instead on our central secure system.
3. By law, we must use procedures and technology to secure personal and financial information throughout the period that we hold or control it, from obtaining to destroying information.
4. Personal and/or financial information must not be transferred to any person to process (ex: while performing services for us or on our behalf), unless that person has either agreed to comply with our data security procedures or we are satisfied that other adequate measures exist.
5. Security procedures include:
   1. Physically securing information. Any desk or cupboard containing confidential information must be kept locked. Computers should be locked with a password or shut down when they are left unattended and discretion should be used when viewing personal or financial information on a monitor to ensure that it is not visible to others.
   1. Virtually securing information. Employees must not share log-in credentials with co-workers. All access instructions, passwords, and account information will be kept in a two-factor authentication cloud storage program with AES encryption and an SSL Secure Connection for business continuity purposes.
   1. Controlling access to premises. Staff should report to security if they see a person they do not recognize in an entry-controlled area.
      
      

Disciplinary Consequences

All principles described in this policy must be strictly followed. A breach of data protection guidelines will invoke disciplinary and possibly legal action.