GDPR

Review our GDPR Policy below

General Data Protection Regulation (GDPR)

Beginning 25th May 2018. The EU General Data Protection Regulation (GDPR) replaces the 1995 EU Data Protection Directive. The GDPR strengthens the rights of individuals regarding personal data relating to them and seeks to harmonise data protection laws across Europe, regardless of where that data is processed.

You can rest assured that Creative Networks is committed to GDPR compliance. We are committed to helping our customers comply with the GDPR by providing stringent privacy and security protections that are built into our service and contracts.

Responsibilities as a customer?

Creative Networks customers will typically act as the data controller for any personal data they provide to Creative Networks in connection with their use of our services. The data controller determines the purposes and means of processing personal data, while the data processor processes data on behalf of the data controller. Creative Networks is a data processor and processes personal data on behalf of the data controller when they use the Creative Networks Managed Services.

Creative Networks provides access to third party services who in their regard act as Data Processors.

Creative Networks is a Data Controller in its own regard when we hold specific data about our customers in order to provide our services.

Data controllers are responsible for implementing appropriate technical and organisational measures to ensure and demonstrate that any data processing is performed in compliance with the GDPR. Controllers obligations relate to principles such as lawfulness, fairness and transparency, purpose limitation, data minimisation, and accuracy, as well as fulfilling data subjects rights with respect to their data.

If you are a data controller, you may find guidance related to your responsibilities under GDPR by regularly checking the website of your national or lead data protection authority. In the UK this is the Information Commissioners Office.

As a Data Controller, you should seek independent legal advice relating to your status and obligations under the GDPR, as only a lawyer can provide you with legal advice specifically tailored to your situation. Nothing on this website is intended to provide you with, or should be used as a substitute for, legal advice.

Where should you start?

As a current or future customer of Creative Networks, you need to be prepared and compliant with GDPR. Here are some considerations:

  • Familiarise yourself with the provisions of the GDPR.
  • Create an updated inventory of personal data that you handle. You can use Creative Networks to help identify and classify data.
  • Review your current controls, policies, and processes to assess whether they meet the requirements of the GDPR. If not, build a plan to address any areas that need amending.
  • Consider how you can leverage the existing data protection features on Creative Networks as part of your own regulatory compliance framework.
  • Regularly Monitor updated regulatory guidance as it becomes available.
  • Consult a lawyer to obtain legal advice specifically applicable to your business circumstances.

Creative Networks commitments to the GDPR

Alongside other duties, data controllers are required to only use data processors that provide adequate guarantees to implement appropriate technical and organisational measures so that data processing will meet the requirements of the GDPR. Here are some aspects you may want to consider when conducting your assessment of Creative Networks:

FAQs

DUE DILIGENCE Q & A

Data Protection Officer

What’s the name and contact details of your Data Protection Officer?Azeem Javed – aj@creative-n.com

Accreditations

What security accreditations you have?Cyber Security Essentials

Systems and applications

Where is your data centre located?Rochdale & Manchester, UK
Will the space in your data centre be shared with any other clients?No, we have a dedicated infrastructure
What measures are in place to protect the physical security of data centres where our data will be stored?Data centres are owned and managed by Iomart. Infrastructure at the head office and Data centres are owned by Creative Networks
Who has access to our data?Our Customer Services team
Is our data on your servers encrypted at rest?Yes

Business continuity

Do you have a business continuity plan that is reviewed, tested and updated at least annually?Yes
When was the business continuity plan last tested?January 2018

User access

Who within your organisation will have access to the personal data?Our Customer Services Team
What user authentication do you use on networks/systems that store/process our data?Our Customer Services team can access your data via a secured database. This function can only be accessed from our offices.

Access to data is restricted to internal access only and 2FA

How often are user accounts reviewed for suitability of access levels?Proactively monitored
What are your password complexity policies?We have a password policy and it is reviewed regularly

Penetration / security testing

Do you conduct penetration testing at least annually on all networks hosting our data?Yes, annually.

Physical security

Could you please describe the physical security that protects our data, including building access and physical server access?Physical security to our servers is managed by Iomart for the datacentre and physical security to our offices is managed by us.

Anti-virus

Do all devices hosting or connecting to our data have AV which is updated at least daily, runs a scheduled scan at least daily, and runs on execution?Yes, all our laptops use Eset Endpoint our servers use Eset.

Application development

What procedures do you have in place to ensure that acceptance criteria for new information systems, upgrades and versions are established and tests are performed prior to roll out?We have a secure development policy. The development life cycle is the standard Business Requirements  Functional Specification  Technical Specification Development Units Tests QAUAT Live
Describe the segregation of duties, including the separation of development, test and operational facilities?We have separate environments for Development, System Testing, UAT and Live
Is production data used in test or development environments?No

Logs

Do you keep and regularly review access, event, error and transaction logs on all networks storing/processing our data?Yes
Are all logs protected from deletion and/or amendment?Yes
Is access to all logs recorded and monitored?Yes

Breach notification

Do you have a formal breach notification process?Yes
What is the timelines to notify us of any suspected breach?We would notify you without delay
Have you had a security breach within the last 12 months? If so, please describe the incident, effect and outcome.No

Data retention / deletion

For what period do you retain our data?We never delete your data
For what period is our data stored in back-ups?We have a 30 day backup rotation period
Where are our backups kept?Slough, UK

Data encryption

Is Personal Data encrypted in transit? Explain howYes, using https protocol
Is Personal Data encrypted at rest? Explain howYes, using Eset Endpoint Encryption

Territories

Is any our processed, stored or transferred outside of the EEA?No

Sub-processors

Is our data passed on to any third parties for processing?No, however we use Iomart for hosting some of our Infrastructure.

Email transmission is done via Office 365 and mail security solution (everycloud).

Backups are encrypted onsite prior to backing up to a Data centre in the UK.

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