Data Security Statement
Last updated: 01 May 2018
"Travelscoop / travelscoop.co.uk / we / us / our / the Company": relates to Mixed Message Media Ltd, trading as travelscoop.co.uk.
"Personal Data": any information relating to an identified or identifiable natural person that is processed by you or us as a result of, or in connection with, the provision of the Services; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal data does not include anonymised data.
"Processing / processes / process": either any activity that involves the use of Personal Data or as the Data Protection Legislation may otherwise define processing, processes or process. It includes any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording. organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Processing also includes transferring Personal Data to third parties.
"Website / Site": The domains https://travelscoop.co.uk and all sub-domains.
All Definitions used in this Policy can be found in a separate Definitions document, which applies across all our policies.
We ensure that we, and all our employees, agents, contractors, volunteers, and other parties working on our behalf comply with the following technical data security measures when working with personal data:
- We use a secure server for our entire Site. All supplied personal information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our database to be only accessed by those authorised with special access rights to our systems, who are required to keep the information confidential.
- Every email that we send is encrypted;
- Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hardcopies should be shredded, and electronic copies should be deleted securely.
- Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
- Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
- Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;
- No personal data shall be sent by facsimile transmission;
- Where personal data is transferred in hardcopy form it should be passed directly to the recipient;
- All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet or similar;
- No personal data may be transferred to any employees, agents, volunteers, contractors, or other parties, whether such parties are working on our behalf or not, without the authorisation of the senior executive responsible for data protection;
- Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, volunteers, agents, sub-contractors or other parties at any time;
- If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it;
- No personal data should be transferred to any device personally belonging to an employee or volunteer and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on our behalf where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Regulation (which may include demonstrating to us that all suitable technical and organisational measures have been taken);
- All personal data stored electronically should be backed up with appropriate software based backup systems. All backups should be encrypted. All electronic copies of personal data should be stored securely using passwords and data encryption;
- All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols;
- Under no circumstances should any passwords be written down or shared between any employees, volunteers, agents, contractors, or other parties working on our behalf. If a password is forgotten, it must be reset using the applicable method.
We also ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
- We strictly limit access to your personal data. Our live database is only accessible to two key employees. All other employees, agents, contractors and other third parties who have a business need to know such data will receive it in anonymised form;
- We maintain a list of employees, volunteers, agents, sub-contractors or other parties who have access to personal data controlled by the Company, and which data is accessed by whom, and this list will be kept up-to-date;
- All employees, volunteers, agents, contractors, or other parties working on our behalf are made fully aware of both their individual responsibilities and the Company’s responsibilities under the Regulation and under this Policy, and are provided with a copy of this Policy;
- No personal data may be shared informally and if an employee, agent, volunteer, sub-contractor, or other party working on our behalf requires access to any personal data that they do not already have access to, such access should be formally requested from the senior executive responsible for data protection;
- All employees, volunteers, agents, contractors, or other parties working on our behalf handling personal data will be appropriately trained to do so;
- All employees, volunteers, agents, contractors, or other parties working on our behalf handling personal data will be appropriately supervised;
- Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;
- The performance of those employees, volunteers, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
- All employees, volunteers, agents, contractors, or other parties working on our behalf handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;
- All agents, contractors, or other parties working on our behalf handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Regulation;
- Where any agent, contractor or other party working on our behalf handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
Physical address of the data servers holding customers’ data
Our server infrastructure is located in Dublin, Ireland, at a secure Amazon Web Services (AWS) data centre. AWS is fully compliant with GDPR legislation. More information on the security of AWS services can be found at https://aws.amazon.com/security/.
All of the personal data that we hold is encrypted at rest, and all communications between our servers and database is encrypted. Our emails are also encrypted.
Access to the data by the officers / employees / subcontractors
We strictly limit access to our live database to two key employees. It is possible for these two employees to access the personal data that we process on your behalf, but strict security protocols and processes mean that this only happens for the purposes of providing the services that we agree to provide to you. We do not provide access to your personal data held in our database to any third parties.
When we might need to access your data
Our systems will work with your personal data when necessary to process it on your behalf (e.g. to provide our Email newsletter service). In order to provide technical assistance we might ask for access to your account and the personal data that you store in it, but that would only happen in extreme circumstances and with your permission.
Data backups and recovery
Our main database is located in Dublin, London. We back up our live database every 5 minutes to two further Amazon Web Services facilities based in the EU region. In the event of service failure due to a physical or technical incident, our full system can be restored and redeployed into an unaffected region within 20 minutes, ensuring that you will be able to gain access to, and amend or delete, your personal data within a very short time frame.
Your passwords are protected by a strong one way hash algorithm. This means our employees can’t see your passwords, and there is no way to retrieve them if forgotten. If you lose your password, you must reset it through triggering an automated email.