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DATA PROTECTION AND
INFORMATION SECURITY POLICY STATEMENT
1. Policy Statement
Maintel is a leading communications services company and this policy applies to
all Maintel employees and any other party or individual who processes data and
personal data on Mantel’s behalf and/or the use of www.maintel.co.uk (“Our
Site”), the Maintel Integrated Management System (IMS) and all of the company
locations and applicable work sites.
Maintel consider Information Security aspects as a top priority for customer
confidence, legal, regulatory and contractual compliance and the protection of
the Maintel brand. We understand that your privacy is important to you and that
you care about how your personal data is used and shared. Maintel respect and
value the privacy of everyone and where required in its ordinary course of
business, Maintel must often necessarily control and process information about
data subjects, i.e. Prospects, Customers, Suppliers and Employees. When handling
such information, Maintel or any party that controls or processes personal data
on Mantel’s behalf, must comply with all current regulations and relevant
contractual obligations. The relevant regulation for this policy is The General
Data Protection Regulation (EU 2016/679) “GDPR”. Accordingly, Maintel commits to
ensuring all information is handled in a secure manner whilst maintaining the
IMS to meet regulatory requirements and elected certifications and
accreditations.
Our Site may contain links to other websites, and wherever that occurs, it is
important to note that Maintel will have no control over how your data is
collected, stored, or used by such websites. Maintel advise you to check the
privacy policies of any such websites before providing data to them.
Maintel take compliance with this policy very seriously. The importance of this
policy means that internal failure to comply with any requirement may lead to
disciplinary action under our procedures which may result in dismissal.
Please read this Data Protection and Information Security Policy carefully and
ensure that you understand it. Your acceptance of this policy is deemed to occur
upon first use of Our Site, entering pre-contract negotiations and contracted
procurement of products and/or services.
Maintel will:
* Ensure that Maintel management, employees and any other individuals acting on
behalf of Maintel will comply with the requirements of the Data Protection
and Information Security Policy and that confidentiality of information will
be maintained to protect both Maintel and its Customers physical and
electronic information assets from all threats, both internal and external,
deliberate or accidental, including those related to data subjects personal
data and card holder data throughout the organisation.
* Protection of information is set out in terms of;
* Confidentiality: ensuring only persons who are authorised have access to
information.
* Integrity: ensuring the purity, accuracy, and completeness of information.
* Availability: ensuring information, associated assets, and systems can be
accessed when required by authorised persons.
* Regulatory: regarding regulations, laws, and codes of practice in each
country where it operates as a minimum standard in its Information security
management standard.
* Minimise the risk of damage to company assets, information, reputation,
hardware, software, or data.
* Ensure that Maintel people and computer systems do not infringe any
copyright, licensing, or laws.
* Set out clearly the company’s policies relating to all aspects of the
management of information, personal data, hardware, firmware, software and
prevention and detection of malware.
* Define a systematic approach to risk assessment by identifying a method that
is suited to the Maintel Integrated Management System (IMS), the identified
business information security, legal and regulatory requirements and setting
policy and objectives for the IMS to reduce risks to acceptable levels.
* Maintain Business continuity plans and test them as appropriate (as far as
practicable)
* Provide Appropriate training for all employees
* Maintain the IMS by a schedule of Internal audits carried out by competent
auditors
* A commitment to continual improvement of the information security management
system
The Head of Information Security has direct responsibility for maintaining the
Security Policy and providing advice and guidance on its implementation.
All managers are directly responsible for implementing the Data Protection and
Information Security Policy within their business areas, and for adherence by
their staff.
It is the responsibility of each member of staff to adhere to the Data
Protection and Information Security Policy.
The overall responsibility for ensuring that the Policy is implemented,
developed, and reviewed effectively rests with the Chief Executive Officer. This
responsibility will be delegated throughout the management structure reflecting
our continued commitment to Information Security at all levels throughout
Maintel.
This statement represents our general position on data Protection and
Information Security issues, and the policies and practices we will apply in
conducting our business.
Joanne Ballard
ESG Strategy and Compliance Director
2. Business Continuity
The purpose of the Business Continuity/Disaster Recovery is to ensure that all
critical Company business activities can be kept at normal or near-normal
performance following an incident that has the potential to disrupt business
operations. All Maintel offices are included within the scope of this policy;
The following areas are covered within the BCP;
* Building Inaccessibility
* Civil Unrest – Act of terrorism
* Civil Unrest – Chemical attack
* Civil Unrest – Public Disorder
* Communications Outage
* Fire Event
* Flood or Water Event
* Industrial Espionage
* Natural Disaster
* Pandemic / Epidemic
* Power Outage
* Severe Weather disruption
* System Outage from a Cyber Attack
Areas covered by the BCP are reviewed, at a minimum, annually and at the time of
an event and adjusted, as necessary.
It is our Policy to ensure that:
* Provision of products and services is maintained as near to normal as
possible
* We identify through appropriate risk assessment, the events that may cause an
event and mitigate those risks as far as possible
* An incident timeline is minimised during any disaster event and operations
return to as near normal as possible in the shortest time frame.
* All teams are aware of how to identify, report and safely work during a
disaster event
* Regulatory and legislative requirements are met
* Appropriate communication and training will be provided for all employees
* Our BC/DR is maintained by a schedule of tests and Internal audits
Each department is responsible for preparing and maintaining current and
comprehensive business continuity plans (BCP) for its operations. Certain
departments, such as Systems/IT, are also responsible for disaster recovery
plans (DRP) to ensure that any damage or disruptions to critical assets can be
quickly minimised and that these assets can be restored to normal or near-normal
operation in a minimum time frame.
When a plan is completed, approved, and implemented, each plan will include
procedures and support arrangements which ensure on-time availability and
delivery of customer products and services. The BC/DR plans are certified
annually through external audit.
Maintel recognises the importance of an active and fully supported BC/DR program
to ensure the safety, health and continued availability of its employees and the
production and delivery of services for customers.
To drive continual improvement within the BC/DR, Maintel set objectives on an
annual basis as part of the Management Review Process; these objectives ensure
the system is appropriately monitored and measured.
All objectives are communicated to staff and include key responsibilities,
timescales, and appropriate measures of success.
3. Cookies
3.1 Our use of Cookies
Our Site may place and access certain first party Cookies on your computer or
device. First party Cookies are those placed directly by Maintel and are used
only by Maintel. We use Cookies to facilitate and improve your experience of Our
Site and to provide and improve our products and/or services. We have carefully
chosen these Cookies and have taken steps to ensure that your privacy and
personal data is always protected and respected.
By using Our Site, you may also receive certain third-party Cookies on your
computer or device. Third party Cookies are those placed by websites, services,
and/or parties other than us. Third party Cookies are used on Our Site for
performance. These Cookies are not integral to the functioning of Our Site and
your use and experience of Our Site will not be impaired by refusing consent to
them.
All Cookies used by and on Our Site are used in accordance with current and
applicable “Cookie Law”.
Please refer to Our Site under Cookie Choices, to provide consent where you
choose to. By giving your consent to the placing of Cookies you are enabling us
to provide the best possible experience and service to you. You may, if you
wish, deny consent to the placing of Cookies; however certain features of Our
Site may not function in part, fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems
these Cookies to be “strictly necessary”. These Cookies are shown below. Your
consent will not be sought to place these Cookies, but it is still important
that you are aware of them. You may still block these Cookies by changing your
internet browser’s settings, but please be aware that Our Site may not work
properly if you do so. We have taken great care to ensure that your privacy is
not at risk by allowing them.
The following first party Cookies may be placed on your computer or device:
Name of Cookie
Purpose
Strictly Necessary
eu_necessary_cookie
EU cookie banner
Yes
eu_performance_cookie
EU cookie banner
Yes
Our Site uses analytics services provided by Google Analytics. Website analytics
refers to a set of tools used to collect and analyse anonymous usage
information, enabling us to better understand how Our Site is used. This, in
turn, enables Maintel to improve Our Site and the products and/or services
offered through it. You do not have to allow Maintel to use these Cookies,
however whilst our use of them does not pose any risk to your privacy or your
safe use of Our Site, it does enable us to continually improve Our Site, making
it a better and more useful experience for you.
The analytics service used by Our Site uses the following Cookies:
Name of Cookie
First / Third Party
Provider
Purpose
_ga
Third
Google analytics
Performance
Expires after 2 years
_gat
Third
Google analytics
Performance
Expires after 10 minutes
_gid
Third
Google analytics
Performance
Expires after 10 minutes
Wp
Third
Act On
Visitor Activity
Persistent
_clck
Third
Microsoft Clarity
Persists the Clarity User ID and preferences, unique to that site, on the
browser. This ensures that behaviour in subsequent visits to the same site will
be attributed to the same user ID.
_clsk
Third
Microsoft Clarity
Connects multiple page views by a user into a single Clarity session recording.
CLID
Third
Microsoft Clarity
Identifies the first-time Clarity saw this user on any site using Clarity.
ANONCHK
Third
Microsoft Clarity
Indicates whether MUID is transferred to ANID, a cookie used for advertising.
Clarity doesn’t use ANID and so this is always set to 0.
MR
Third
Microsoft Clarity
Indicates whether to refresh MUID.
MUID
Third
Microsoft Clarity
Identifies unique web browsers visiting Microsoft sites. These cookies are used
for advertising, site analytics, and other operational purposes.
SM
Third
Microsoft Clarity
Used in synchronizing the MUID across Microsoft domains.
3.2 Managing Cookies
In addition to the controls that Maintel provide, you can choose to enable or
disable Cookies in your internet browser. Most internet browsers also enable you
to choose whether you wish to disable all cookies or only third-party Cookies.
By default, most internet browsers accept Cookies, but this can be changed. For
further details, please consult the help menu in your internet browser or the
documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however
you may lose any information that enables you to access Our Site more quickly
and efficiently including, but not limited to, login and personalisation
settings.
It is recommended that you keep your internet browser and operating system
up-to-date and that you consult the help and guidance provided by the developer
of your internet browser and manufacturer of your computer or device if you are
unsure about adjusting your privacy settings.
4. Data Protection
4.1 Data Protection Principles
All employees and sub-contractors of Maintel shall abide by the Data Protection
Principles when carrying out any activity that contains Personal data. All
personal data shall be:
* Processed lawfully, fairly and in a transparent manner;
* Collected for specified, explicit and legitimate purposes;
* Adequate, relevant and limited to what is necessary;
* Accurate and, where necessary, kept up to date;
* Retained only for as long as is necessary;
* Processed in a manner that ensures security
4.2 Your Rights
As a data subject, you have the following rights under GDPR, which this policy
and Maintel use of personal data have been designed to uphold;
* The right to be informed about Maintel collection and use of personal data;
* The right of access to the personal data Maintel hold about you;
* The right to rectification if any personal data Maintel hold about you is
inaccurate or incomplete (please contact Maintel using the details in section
6);
* The right to be forgotten – i.e. the right to ask Maintel to delete any
personal data Maintel hold about you (Maintel only hold your personal data
for a limited time, as explained in this policy but if you would like Maintel
to delete it sooner, please contact us using the details in section 6);
* The right to restrict (i.e. prevent) the processing of your personal data;
* The right to data portability (obtaining a copy of your personal data to
re-use with another service or organisation);
* The right to object to Maintel using your personal data for particular
purposes; and
* Rights with respect to automated decision making and profiling.
* Please note that Maintel does not ordinarily utilise automated decision
making, including profiling in the normal course of its activities.
If you have any cause for complaint or would like to talk to us about Maintel
use of your personal data, please contact us using the details provided in
section 6 below and we will do our best to solve the problem for you as soon as
reasonably possible. If we are unable to help, you also have the right to lodge
a complaint with the UK’s supervisory authority; the Information Commissioner’s
Office.
For further information about your rights, please contact the Information
Commissioner’s Office or your local Citizens Advice Bureau.
4.3 What data do we collect?
Depending upon your interaction with Maintel and use of Our Site, Maintel may
collect some or all of the following personal data and non-personal data, please
also see the Cookies section on Maintel use of Cookies and similar technologies;
* Name
* Business/Company Name
* Job Title
* Contact Information such as email addresses and telephone numbers
* Main location, site/installation and billing Address(es) and Postcode(s)
* IP Address
* Call Records
* Employee Number / Identification Number
* Web browser type and version
* Operating system
* A list of URLs’ starting with a referring site, your activity on Our Site,
and the page you exit from
4.4 How do we use your Data?
All personal data is only ever processed and stored securely, for no longer than
is necessary and for the purpose for which it was first collected. Maintel
always comply with our obligations and safeguard your rights under Data
Protection Regulations in force. For more details on security see section 4.5,
below.
Our use of your personal data will always have a lawful basis, ie; because it is
necessary for the performance of a contract with you, because you have consented
to the use of your personal data (e.g. by subscribing to emails) or because it
is in our ‘legitimate interests’ as defined and prescribed in the GDPR.
Specifically, Maintel may use your data for the following purposes:
* Providing and managing your Account;
* Providing and managing your access to Our Site;
* Personalising and tailoring your experience on Our Site;
* Supplying products and/or services to you (please note that Maintel require
your personal data in order to enter into a contract with you);
* Personalising and tailoring Maintel products and services for you and your
business
* Replying to emails from you;
* Supplying you with emails that you have opted into (you may unsubscribe or
opt-out at any time by clicking the unsubscribe link in our emails);
* Analysing your use of Our Site and gathering feedback to enable Maintel to
continually improve Our Site and your user experience;
With your permission and/or where otherwise permitted by law, Maintel may also
use your data for marketing purposes which may include contacting you by email
and/or telephone and/or text message and/or post with information, news and
offers on Maintel products and/or services. We will not, however, send you any
unsolicited marketing or spam and will take all reasonable steps to ensure that
we fully protect your rights and comply with obligations under the current Data
Protection regulations and the Privacy and Electronic Communications (EC
Directive) Regulations 2003.
Third parties whose content appears on Our Site may use third party Cookies, as
detailed in the Cookies section. Please refer to the Cookies section within this
document 3 for more information on controlling Cookies. Please note that we do
not control the activities of such third parties, nor the data they collect and
use and advise you to check the privacy policies of any such third parties.
You have the right to withdraw your consent to Maintel using your personal data
at any time, and to request that Maintel delete it.
Maintel do not keep your personal data for any longer than is necessary in light
of the reason(s) for which it was first collected. Data will therefore be
retained for the following periods (or its retention will be determined on the
following bases):
* Marketing contact information: Until permission is withdrawn, i.e.
Unsubscribe
* In accordance with contractual obligations; full term of agreement plus 7
additional years
* Cardholder data is not retained for any reason
4.5 How and where do we store your Data?
We only keep your personal data for as long as we need to in order to use it as
described above in section 4.4, and/or for as long as we have your permission to
keep it.
Data security is very important to Maintel, and to protect your data we have
taken suitable measures to safeguard and secure data collected. Some or your
data may be stored outside of the European Economic Area (“the EEA”) (The EEA
consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If
Maintel do store data outside the EEA, we take all reasonable steps to ensure
that your data is treated as safely and securely as it would be within the UK
and under the current Data Protection regulations.
Steps Maintel take to secure and protect your data include;
* Contractual agreements with Third Parties
* Technical and Organisation security measures provided within;
* ISO 27001 – Information Security
* Payment Card Industry Data Security Standard (PCI-DSS)
* Cyber Essentials Plus
* Supplier Security and Privacy risk assessment and review
4.6 Do we share your Data?
In certain circumstances, Maintel may be legally required to share certain data
held by us, which may include your personal data, for example, where Maintel are
involved in legal proceedings, where we are complying with legal obligations, a
court order, or a governmental authority.
We may sometimes contract with third parties to supply products and services to
you on our behalf. These may include payment processing, delivery of goods and
services, search engine facilities, advertising, and marketing. In some cases,
the third parties may require access to some or all of your data. Where any of
your data is required for such a purpose, we will take all reasonable steps to
ensure that your data will be handled safely, securely, and in accordance with
your rights, our obligations, and the obligations of the third party under the
law.
We may also compile statistics about the use of Our Site including data on
traffic, usage patterns, user numbers and other information. All such data will
be anonymised and will not include any personally identifying data, or any
anonymised data that can be combined with other data and used to identify you.
We may from time to time share such data with third parties such as prospective
investors, affiliates, partners, and advertisers. Data will only be shared and
used within the bounds of the law.
4.7 What happens if Maintel changes hands?
Maintel may, from time to time, expand or reduce the business and this may
involve the sale and/or the transfer of control of all or part of our business.
Any personal data that you have provided will, where it is relevant to any part
of our business that is being transferred, be transferred along with that part
and the new owner or newly controlling party will, under the terms of this
Privacy Policy, be permitted to use that data only for the same purposes for
which it was originally collected by Maintel.
4.8 How can you control your Data?
When you submit personal data via Our Site, you may be given options to restrict
our use of your data. In particular, we aim to give you strong controls on our
use of your data for direct marketing purposes (including the ability to opt-out
of receiving emails from us which you may do by unsubscribing using the links
provided in emails and at the point of providing your details).
You may also wish to sign up to one or more of the preference services operating
in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone
Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”).
These may help to prevent you receiving unsolicited marketing. Please note,
however, that these services will not prevent you from receiving marketing
communications that you have consented to receiving.
4.9 Your right to withhold information
You may access Our Site without providing any data at all. However, to use all
features and functions available on Our Site you may be required to submit or
allow for the collection of certain data.
You may restrict Maintel use of Cookies. For more information, see Cookies
section within this document.
4.10 How can you access your Data?
You have the right to ask for a copy of any of your personal data held by
Maintel (where such data is held). Under the GDPR, no fee is payable, and we
will provide any and all reasonable information in response to your request free
of charge. Please contact Maintel for more details at
subjectaccessrequest@maintel.co.uk, or using the contact details below in
section 6.
5. Risk Management
The purpose of this policy is to describe Maintel risk management framework and
how risks will be identified, assessed, monitored, and reported within the
business at the corporate level.
Risk management is a process which aims to help businesses understand, evaluate
and take action on all their risks with a view to increasing the
probability of achieving their objectives and reducing the likelihood of
failure. Risk management gives comfort to stakeholders that the business is
being effectively managed and helps the business confirm its compliance with
corporate governance requirements.
It is our policy to;
* identify risks in relation to the achievement of our objectives
* assess their relative likelihood and impact
* respond to the risks identified, considering our assessment
* review and report on risks to ensure that Maintel risk profile is up to date,
to provide assurance that responses are effective, and identify when further
action is necessary.
By successfully implementing our Policy we expect to:
* successfully achieve our objectives and minimise the risk of failure
* take a proactive approach, anticipating and influencing events before they
occur
* facilitate better informed decision making
* improve our contingency planning.
The Risk Management Policy is regularly reviewed and approved by the Board.
Accountability and Responsibility
The table summarises the responsibility of the various risk management
responsibilities:
Body
Roles and responsibilities include:
Board
Set the tone for risk management including risk appetite
Have overall responsibility for the risk management arrangements
Periodically review the corporate risk register,
Receive reporting of any new major risks
Horizon scanning and consideration of emerging risks
Audit and Risk Committee
Ensure the approach to risk management is sound and operating as intended
Challenge the risk register, the scoring, the risks on the register
Monitor actions and processes to ensure compliance
Assess the level of assurance on the controls in place
Horizon scanning and consideration of emerging risks
Executive directors
Periodically review, update, and amend the entire risk register
Challenge the risks, scores, and mitigations of other risk owners
Recommend where further mitigating actions may be required
Governance Team Leader
Act as an advocate for risk management across all levels of the business
Responsible for the development of the business’s risk management procedures
subject to approval by the Board
Drafting the Risk Management Policy for the Board approval and presenting it for
review and approval periodically
Co-ordinate the risk management activities of the management team and IMS
management team and escalating new risks to the appropriate risk register
Compile risk information and reports for the Executive team and Board
Providing risk management update reports to the Board
Monitoring the application of the Risk Management Policy.
IMS Management Team
Responsible for the Security and Health and Safety Risk Assessments and the
Environmental Significance Assessment
Identify specific categories of activity/asset and the threats that can impact
them
Set “rules of engagement” for the use of the asset or whilst conducting the
activity
Record the appropriate legislation, location and owner for each activity/asset
Identify precautions and recommend the actions to be taken to protect the
activity/asset
Risk Owners
Embed the risk management culture within the business
Identify and score risks at gross and net levels
Monitor the operation of controls to ensure that they are operating with
sufficient effectiveness to justify the residual/net risk score
Identify and report changes in the external or internal environment that can
influence the risk profile
All Staff
Understand, accept, and implement risk management processes within their areas
of operation
Be alert to risks associated with the activities that they perform
Report to Risk Owners inefficient, unnecessary, or unworkable controls
Report to Risk Owners losses and near misses
Maintel is a leading communications services company managing technology
consolidation and delivering integrated solutions encompassing telephony, data
networks, mobile and wireless, consultancy services, contact centres and
business document print and management solutions throughout the UK.
Maintel is committed to providing the best possible experience to its customers,
employees, shareholders, and suppliers. To ensure the consistent availability
and delivery of its products and services, Maintel has developed the following
business continuity and disaster recovery (BC/DR) policy in support of a
comprehensive program for BC, DR and overall business survivability.
Maintel, like any other business, is exposed to potential risks that could
disrupt or destroy critical business functions and/or the production and
delivery of services to our customers. Our strategy for continuing business in
the event of a disaster is to ensure the safety and security of all employees
and to continue critical business functions, production, and delivery of
services from predefined alternative sites.
6. General Information
* Changes to Maintel Policy: We may change this Policy from time to time (for
example, if the law changes). Any changes will be immediately posted on Our
Site and you will be deemed to have accepted the terms of the updated Policy
on your first use of Our Site following the alterations. We recommend that
you check regularly to keep up to date.
* Contacting Maintel: If you have any questions about this Policy, please
contact us by email at gdpr@maintel.co.uk, by telephone on +44(0)344 871
1122, or by post at 160 Blackfriars Road, Southwark, London, SE1 8EZ. Please
ensure that your query is clear, particularly if it is a request for
information about the data Maintel hold about you.
Data Protection Officer: Maintel is not obligated to allocate the position of
Data Protection Officer (DPO) but has chosen to do so. Maintel have engaged GRCI
Law Ltd , Unit 3 Clive Court, Bartholomews Walk, Cambridgeshire Business Park,
Ely, Cambs CB7 4EA to act as DPO on behalf of Maintel.
Maintel internal contact for Data Protection matters is
* * Name and Job Title: Joanne Ballard, ESG Strategy and Compliance Director
* Email address: gdpr@maintel.co.uk
* Telephone Number: +44(0)344 871 1122
* Address: 160 Blackfriars Road, Southwark, London, SE1 8EZ
* Maintel Europe Ltd: is a limited company registered in England under company
number 023665837, whose registered address is 160 Blackfriars Road, London,
England, SE1 8EZ, and whose main trading address is 160 Blackfriars Road,
London, England, SE1 8EZ.
* Reporting Data Breaches: All actual or potential personal data breaches shall
be reported as soon as they become known using Maintel Information Security
Incident process. Suspected or actual data breaches shall be reported to the
Supervisory Authority within 72 hours and the Data Subject/s as soon as
possible.
* Training: All Maintel employees receive Data Protection training during the
annual refresher, at Induction and during job role changes. Line Managers are
responsible for ensuring information and training is provided to all members
of their team.
* www.maintel.co.uk: is owned and operated by Maintel Europe Ltd
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