Data Protection Governance Policy for Rhics Ltd

 

Introduction

Rhics Ltd acknowledges the importance of robust data protection governance to ensure compliance with data protection laws and to safeguard the personal data of our customers, employees, and partners. This policy outlines the governance structure, roles, responsibilities, and procedures for managing and protecting personal data within our organization.

Policy Objective

To establish clear governance processes for data protection that align with legal requirements and best practices. This policy ensures accountability at the highest levels of the organization and continuous oversight of data protection practices.

Governance Structure

Roles and Responsibilities

  • Nominated Director for Data Protection: The Director of Compliance is designated as the accountable officer to the board/CEO for the management of personal data. This director ensures that data protection is prioritized at the board level and that policies are implemented consistently across the organization.
  • Data Protection Officer (DPO): Appointed to oversee data protection strategy and implementation. The DPO ensures compliance with data protection laws and acts as a point of contact for data subjects and regulatory bodies.

Assurance Committee

  • Formation and Composition: The Data Protection Assurance Committee is comprised of senior management from various departments, including IT, Legal, Compliance, and Human Resources.
  • Frequency of Meetings: The committee meets quarterly or more frequently if needed.
  • Agenda Items:
    • Review of recent data/personal information incidents and the responses to these incidents.
    • Updates on changes to data protection laws and regulations.
    • Assessment of current data protection measures and compliance status.
    • Review of data protection training and awareness programs.

Procedures

Data Protection Accountability

  • Board Involvement: Regular reports are provided to the board by the Nominated Director for Data Protection, detailing ongoing compliance efforts, incident handling, and any significant data protection issues.
  • Strategic Decisions: The board, advised by the Data Protection Assurance Committee, makes strategic decisions regarding data protection, ensuring adequate resources are allocated to protect personal data.

Incident Management and Reporting

  • Incident Reporting: All personal data incidents must be reported immediately to the DPO, who will assess the incident and involve the Data Protection Assurance Committee as necessary.
  • Record Keeping: The DPO maintains records of all data protection issues and incidents, including actions taken and their outcomes, to be reviewed during the assurance committee meetings.

Review and Compliance

  • Compliance Audits: Regular audits are conducted to ensure compliance with this policy and data protection laws. Audit results are reviewed by the Data Protection Assurance Committee.
  • Policy Review: This policy is reviewed annually or more frequently if significant changes in data protection legislation or organizational processes occur. Reviews are conducted by the Data Protection Assurance Committee, with changes approved by the board.

Documentation and Communication

  • Policy Documentation: This policy and all related procedures are documented and accessible to all employees.
  • Training and Awareness: Regular training sessions are conducted to ensure that all employees understand their responsibilities under this policy and the importance of protecting personal data.

Conclusion

This Data Protection Governance Policy forms the backbone of Rhics Ltd’s commitment to high standards of data protection. By ensuring clear accountability, regular reviews, and proactive management of data protection issues, Rhics Ltd upholds its obligations to protect personal data and maintain trust with stakeholders.