Privacy Policy & GDPR

Who we are:

Monneo a brand name of E-Pay International LTD; https://www.monneo.com

Our company registration number is: 10086951

E-Pay International LTD is registered with the Financial Conduct Authority as an Authorised Payment Institution with reference number: 802210

Our registered address is: 61-63 Crockhamwell Road, Reading, United Kingdom, RG5 3JP 47.

Office address: Red Lion Street, London, WC1R 4PF, United Kingdom.

Phone: + 44 20 3802 0407
E-Mail: compliance@monneo.com

Data Classification Policy

1. Policy introduction

Here at E-Pay International LTD, we are committed to data security, the privacy of the individual and upholding all our compliance obligations under GDPR. We take our responsibilities seriously, and we recognise that the use of information assets and data form a crucial aspect of our business activity. That is why we’ve devised the following Data Classification Policy to outline the way in which we classify and use data.

Our Data Classification Policy is designed to ensure that:

  • E-Pay International LTD adheres to all necessary legal obligations
  • E-Pay International LTD maintains availability, confidentiality and integrity where necessary for all data
  • Our company has the ability to chart data protection levels that protect both E-Pay International LTD as well as the individuals whose personal data we must collect, process or store
  • We are able to avoid threats of disclosure and/or unauthorised access to data

2. Policy values

Data classification is a vital process our company must carry out to ensure the individuals who claim a legitimate right to access information we hold are able to do so. Our data classification process must also ensure our data and any other piece of information we hold is protected from any and all individuals or organisations that should not have access to that information.

E-Pay International LTD’s Data Classification Policy identifies and elaborates upon the correct handling and classification processes our company must use, as per the regulatory requirements that we:

  • Make data available to all those individuals who have a legitimate reason to access it
  • Manage all data in line with its corresponding classification
  • Maintain the integrity of all data
  • Ensure all data our company holds is accurate, complete and consistent

3. Policy objectives

E-Pay International LTD’s Data Classification Policy has been developed to meet the following objectives:

  • To outline the duties and responsibilities of E-Pay International LTD client that ensure data is kept safe and secure
  • To establish a robust data classification process that is consistent and compliant with UK regulatory requirements
  • To ensure data is sufficiently protected and encrypted so that unwarranted actions will not be taken against E-Pay International LTD in the event data is lost, damaged or accessed illegally
  • To avoid and minimise reputational or operational damage to E-Pay International LTD, our stakeholders, clients, customers or partners associated with compromised data

4. Policy implementation

To make sure our Data Classification Policy is effective, E-Pay International LTD has implemented the following procedures:

  • All users of data will be identified and provided access to data in which they have a legitimate need to access
  • All data will be classified, managed and controlled in relation to its correct categorisation, as per the processes and requirements outlined within this policy
  • E-Pay International LTD must ensure control mechanisms are created and implemented to protect data we collect, process or store
  • All control mechanisms and classification protocols must be reviewed and amended as required by law on a regular basis
  • Data users and data controllers must implement and maintain adequate levels of physical security as required, in relation to computer facilities or access terminals from which data can be viewed or accessed
  • E-Pay International LTD must ensure that all data and relevant equipment is safely disposed of, as and when required

5. Obligations under GDPR (2018) and Data Protection Act 2018 (DPA)

E-Pay International LTD is committed to meet its regulatory obligations under GDPR and DPA. That is why we are committed to ensure that adequate and appropriate measures are taken to prevent the unauthorised access or illegal processing or storage of data. We are required to do everything we can, within reason, to protect the data we use and hold against destruction, accidental loss or damage.

6. Data classifications

Data that is sensitive in nature must be adequately protected at all times. To properly assign safeguards, all data that our company collects, processes or stores must be assigned one of the following classification categories:

  • Public
  • Open
  • Confidential
  • Strictly Confidential
  • Secret

A vast amount of the data E-Pay International LTD uses will most likely be classed as being either ‘Public’ or ‘Open’ data. Any information relating to an individual or organisation that could identify them or is personal or private in nature must be assigned a category of either ‘Confidential’ or ‘Strictly Confidential’.

This is to ensure E-Pay International LTD upholds its regulatory commitment to uphold the rights of individuals, as outlined under GDPR.

On rare occasions, E-Pay International LTD may wish to class data as ‘Secret’. If an employee is unsure as to whether they should categorise a piece of data as being secret – or if they need assistance in classifying any other piece of data, they should consult a line manager. If no manager is available for consultation, data should default to a ‘Confidential’ classification.

7. Data classification types and handling procedures

To minimise discrepancies and ensure E-Pay International LTD does everything it can to uphold its regulatory commitments, the following working definitions should be associated with the aforementioned classification categories.

Public data

Public data is information or data that can be accessed by any external individual or organisation.

Types of public data might include:

  • Official contact data of relevant company employees
  • News updates or press releases
  • Company publications
  • External-facing company policies or procedures

How to handle public data:

Public data should be formatted to allow for the most basic security measures. Examples might include converting a Word document into a PDF to avoid others editing it, as this could subsequently cause some form of reputational damage.

Open

Anyone is able to access this information.

Types of open data might include:

  • Official contact data e.g. full name, primary email address and telephone number
  • Authorised communications, such as blogs, news articles and industry updates
  • Approved company policies, guidance and processes

How to handle open data:

Open data should be formatted to allow for the most basic security measures. Examples might include converting a Word document into a PDF to avoid others editing it, as this could subsequently cause some form of reputational damage.

Confidential data

Access to confidential data must be limited only to individuals who have been granted appropriate authorisation to view or process that information.

Alternatively, there may be occasions in which unauthorised individuals or stakeholders may need to be granted access to confidential data; however, this access must only be provided on a need-to-know basis.

Types of confidential data might include:

  • Someone’s personal details or any information that could be used to identify them. Examples of identifiable or personal details include:
  • Name
  • Date of birth
  • Address
  • Telephone number
  • Email address
  • National Insurance number
  • Passport
  • ID
  • Health details
  • Political affiliations
  • Trade union membership
  • Criminal offences
  • Employee contracts
  • Non-Disclosure Agreements
  • Unfinished or unapproved company documents
  • Employee wage slips
  • Death certificates
  • PDR documentation

How to handle confidential data:

As and where required to handle confidential data, employees should exercise the following handling processes:

  • Paper documents must be:
  • In secure locked storage
  • Transported in sealed envelopes only
  • Transported by an approved third-party courier service
  • Securely disposed of
  • Electronic data must be:
  • Encrypted
  • Password-protected wherever possible
  • Transportation must follow secure file transfer protocol
  • Storage must be limited to secure file stores
  • Securely disposed of

Strictly confidential data

A minimal number of authorised individuals, authorities or other stakeholders may be permitted access to data that has been classified as being ‘Strictly confidential’.

Types of strictly confidential data might include:

  • Bank details
  • Credit card information
  • Financial information
  • Server information
  • Usernames or passwords
  • Test data
  • Disciplinary proceedings
  • Patent information
  • Network information

How to handle strictly confidential data:

As and where required to handle strictly confidential data, employees should exercise the following handling processes:

  • Paper documents must be:
  • In secure locked storage
  • Transported in sealed envelopes only
  • Transported by an approved third-party courier service
  • Electronic data must be:
  • Encrypted
  • Password-protected wherever possible
  • Tagged
  • Transportation must follow secure file transfer protocol
  • Storage must be limited to secure file stores

Secret data

Access to data that has been classed as ‘Secret’ or a request to access secret data is subject to the Official Secrets Act.

Various types of secret data may require different controls and circumstances. Bearing that in mind, individual protocols should be reviewed on a case-for-case basis in line with UK Government requirements. Government advice concerning the handling of secret data should be sought.

8. Data classification markings

Data classification markings need to be clearly visible at all times and must match the classification category in which that data has been assigned. Appropriate data classification identification markings should be included either at the top, bottom or centre of each document page.

9. Reclassifying data

There may be occasions in which data must be reclassified from one data category to another data category. The need for reclassification could depend upon a content change, or an alteration in terms of the data’s intent, where it is stored or how it is being used. Before reclassifying data, a firm and justifiable rationale must be established. If in doubt, contact the Data Protection Officer or your line manager for guidance.

10. Sensitive data

It is the responsibility of the data owner or the data originator to define the category of data classification for a piece of data. Responsibility also rests with the data owner or originator to ensure that adequate protection has been afforded to that data in line with its relevant classification.

Any data that could or should be defined as being personal in nature must be afforded a higher level of protection and be treated as data that is sensitive. Personal data can be classed as information relating to an individual that could identify them. Aforementioned examples of sensitive personal data might include (among other pieces of data) a person’s name, contact information, race, religion, political affiliations, sexual preference and so on.

Sensitive data must be identified and assessed on a case-for-case basis. In most cases, sensitive data will inherently be classed as confidential; thus, access and/or availability must be limited.

Sensitive data which is made available in the public domain can lead to reputational damage for private individuals or company employees. As a company we must ensure that sensitive data is given sufficient protection to protect individuals, company employees and the company itself.

11. Data storage and backup

Because data is such an integral aspect of our business, it is everyone’s responsibility at E-Pay International LTD to do everything within their power to ensure that sensitive data is being collected, processed, backed up, stored and secured in line with company policy.

12. Data anonymisation

Prior to the sharing, transfer or disclosure of data, E-Pay International LTD and its employees must take all necessary steps to ensure that the anonymity of corresponding data subjects is protected and maintained in line with our regulatory commitments.

Necessary steps may include omitting or redacting (deleting) said personal identifiers within a piece of data. Audio visual data or verbally exchanged data recordings should be likewise edited.

13. Secure data disposal

Sensitive data that is no longer needed or has reached an ‘end of life’ classification as decided upon by the relevant authorised individuals must be disposed of in a secure fashion. Examples of disposing data as stored on paper would include shredding.

14. Data security response

If data is damaged or lost, it must be immediately reported to an appropriate line manager and company Data Protection Officer, and logged as an incident requiring urgent response.

DATA SECURITY POLICY

Introduction

Here at E-Pay International LTD, we collect, process and store personal data for a range of business purposes. Data subjects include customers, suppliers, partners, employees, clients and other stakeholders and individuals.

Bearing in mind E-Pay International LTD’s commitment to uphold the rights of the individual as enshrined in law, our data security policy is designed to protect all past, current and future employees, customers, or partners, from illegal or damaging activity conducted by others using their personal data.

Our data security policy outlines how E-Pay International LTD will endeavour to guard and protect all personal data. It also sets out to raise the awareness of staff members in relation to the ways in which GDPR impacts their use of individual’s personal data.

This policy applies to all data processing activities involving E-Pay International LTD, and includes activities or systems related to both internal business operations, as well as external relations and any third-party agreements.

Please note that E-Pay International LTD’s data security policy applies to all employees, Merchants, Contractors and Partners and this policy may be subject to review and amendment on a regular basis. For more information about this policy and its overall implementation, consult our Data Protection Officer.

This document is subject to regular review to ensure ongoing regulatory compliance.

Data security policy definitions

Personal data

Personal data encompasses any type of information that relates to an identifiable individual. Various types of personal data E-Pay International LTD may collect, store and process could include:

  • Contact details
  • Financial information
  • Educational background
  • Certifications
  • Skills
  • Nationality
  • Marital status
  • Job title

The above list is by no means exhaustive, and should be used merely as a point of reference from which a working definition of personal data can be established and further developed.

Sensitive personal data

Under GDPR, sensitive personal data is defined as encompassing any of the following:

  • Racial or ethnic origin
  • Political opinion
  • Religious or philosophical beliefs
  • Trade union membership
  • Genetic data
  • Biometric data
  • Health-related information
  • Sexual orientation

It is paramount that all sensitive personal data is kept under stringent control as part of the implementation of our data security policy.

Purposes of personal data

E-Pay International LTD uses personal data for a range of various purposes. These purposes may include:

  • Financial
  • Administrative
  • Human resources
  • Regulatory compliance
  • Business development

Please note the above list is by no means exhaustive, and should merely be used as a reference point from which a working definition of purpose can be established.

Business purposes

E-Pay International LTD must carry out a range of functions and processes as part of our operational activity. Data kept in relation to these activities falls under the category of data for business purposes, which includes information of the following nature:

  • Operational
  • Compliance
  • Policy adherence
  • Human resources and personnel
  • Marketing

The above list is by no means exhaustive, and should be used merely as a point of reference from which a working definition of business purposes can be established and further developed.

Fair processing

At E-Pay International LTD, there will be occasions when employees will need to process personal data; however, processing activities must always be carried out in a fair and lawful manner that is compatible with the rights of each corresponding individual. Consequently, we should avoid processing the personal data of any individual who has not provided us with explicit consent.

Our company must strive to obtain explicit consent at all costs, and we must clearly identify to the individual what data is being processed, why we need to use it and who will have access to their data. These factors must be identified and clearly reiterated to the individual at the point of request for consent.

It’s worth noting there may be exceptional circumstances in which we are asked to process sensitive personal data without consent. An example of an exceptional circumstance could include legal obligations we may need to carry out to comply with health and safety regulations.

E-Pay International LTD endeavours to take all actions necessary to ensure that all personal data we obtain, process and store is accurate, relevant and adequate in relation to the reason in which we asked for that information. We should not hold excessive or irrelevant data on any individuals, and we will not process any personal data for a purpose unrelated to the purpose in which the relevant individual has consented to the processing of their data.

Our roles and responsibilities

Data security is a critical component of our business. It falls on everyone at E-Pay International LTD to take responsibility for data security, and all employees must familiarise themselves with our data security policy and do everything within their power to uphold that policy on a day-to-day basis.

Please note that E-Pay International LTD takes data protection incredibly seriously, and we expect all staff members to adhere to this data security policy. Any failure and refusal to comply with this policy could ultimately place our company at risk.

Bearing that in mind, personal non-compliance with this data security policy could lead to disciplinary action as they relate to ordinary personnel procedures. Please contact your line manager with any further questions concerning data protection at E-Pay International LTD.

Staff members at E-Pay International LTD, can expect to receive data protection training in line with our data security policy. All incoming employees will be provided training as an aspect of the wider staff induction process, and all staff members can anticipate the requirement to undergo additional training as a result of subsequent regulatory updates to GDPR or other relevant legislation as it relates to data security.

Data security will inevitably encompass a range of additional responsibilities for various roles within the company. These roles and their responsibilities include (but are not limited to):

Data Protection Officer

GDPR stipulates our company must appoint a Data Protection Officer. It is our Data Protection Officer’s responsibility to:

  • Organise data security training for all employees not specifically referenced within this data security policy.
  • Review and analyse all existing data security protocols and processes on a regular basis.
  • Be a point of contact for all employees, clients and stakeholders to answer questions about data protection and data security.
  • Respond to internal or external queries from individuals wanting to know what data relating to them may have been obtained, processed or stored by our company.
  • Conduct due diligence and submit approval in relation to any contractual agreement with a third party involving the processing or storage of data.
  • Maintain constant contact with company directors, board members and stakeholders in relation to data security, company responsibilities and data risk management.

IT Manager

Information technology plays a crucial role in the way our company operates. Any processes relating to IT and the processing and storage of data must be carefully monitored, assessed and guided by an IT Manager.

It is the responsibility of E-Pay International LTD’s IT Manager to:

  • Conduct due diligence and appropriate levels of research into any third-party service that our company may call upon to store or process any data.
  • Make sure that all company software, IT systems, equipment and services meet changing levels of data security standards.
  • Carry out regular checks, audits and scans to ensure security hardware and security software are fully functional and optimised to manage and mitigate data security risks.

Marketing Manager

A significant proportion of our marketing activities involve the collection, storage and processing of data. Consequently, our Marketing Manager must oversee the following responsibilities:

  • Accept all queries relating to data security and data protection from leads, media outlets, clients or other individuals and oversee and deliver an adequate response.
  • Work alongside E-Pay International LTD’s Data Protection Officer to make sure that all of our marketing processes, campaigns and activities are compliant with all relevant data security and data protection laws – as well as our own company data security policy.
  • Review, draft and approve any relevant data security statements that must accompany emails, other messages or applicable marketing collateral.

Our data security policies

E-Pay International LTD takes data security extremely seriously, and we place the rights of the individual and regulatory adherence at the heart of everything we do as a company.
In light of our commitments, it is mandatory all staff members must observe and adhere to the following data security policies:

Data storage policy

  • All information or data that is collected and processed is subject to all of the applicable requirements as outlined and documented within this policy. This includes information collected electronically, by paper, telephone or data collected through any other means.
  • All data must be collected, stored and protected in a secure location appointed by E-Pay International LTD, for a retention period as predefined by corresponding legislature or company policy.
  • Staff members are strictly forbidden to retain confidential information or personal data not relating to themselves on their personal devices. Exceptions to this policy include information that is needed for a purpose that is work-related, temporary and specified and approved by a relevant manager.
  • Staff members should avoid downloading sensitive files or confidential information to local devices wherever possible. Information being necessarily processed for work purposes may be exempt from this policy.
  • Employees must install and use software and systems that have been licensed and approved by the company on devices while carrying out the duties of their role. Downloading or using any software, app or system that is not pre-approved by the company will require prior approval from the company’s IT Manager.
  • All mobile and portable devices used by staff members should be approved by the company’s IT Manager and secured to prevent unauthorised access or breach. Personal devices could include a laptop, smartphone, tablet or any other handheld computing devices. This policy also applies to any shared cloud storage spaces.
  • All internet access and online operations carried out by employees could be subject to monitoring and filtering in accordance with relevant legislation and company policy. This monitoring should be carried out only by the IT Manager or an authorised member of staff.
  • Employees must adhere to all applicable elements of this policy when using personal devices to access company resources. Similarly, employees must observe and adhere to all applicable elements of this data security policy when using equipment provided by E-Pay International LTD to access information externally.
  • Employees are forbidden from using public access devices. This practice is allowed in some circumstances; however, prior and explicit approval from a line manager for regular public access must be obtained and recorded.
  • Employees must use access tools provided to them by a client or partner of E-Pay International LTD if access is granted to any third-party storage system or data storage facility.
  • It is forbidden to send, forward or submit any of the information or data referred to within this data security policy to a third-party unless deemed essential to complete approved processes.
  • If an employee needs to carry out an approved submission of data to any relevant third-party, that data must be made secure in accordance with company policy and any relevant third-party data protection protocols.

Please note that E-Pay International LTD will carry out regular system audits to monitor and ensure ongoing compliance with this data security policy and all regulatory requirements as outlined under GDPR.

Data retention policy

While E-Pay International LTD must routinely collect and store data, we are committed to the rights of individuals. That’s why we retain all information and personal data for no longer than we need to.
The necessary length of retention will often be decided on a case-for-case basis, bearing in mind the rationale and original purpose surrounding data collection and retention. Decisions of this nature must be made in a way that is compatible with our existing data retention guidelines under GDPR.
For additional guidance, consult the following corresponding documents:
  • Data retention and erasure policy document

International data transfer policy

Employees must observe a series of restrictions that apply towards the international transfer of data or personal information. Employees are not permitted to transfer personal information or data outside of the United Kingdom without having obtained explicit permission in the first instance from the company’s Data Protection Officer.

Data encryption and anonymisation policy

E-Pay International LTD deploys encryption to secure and protect data that is stored on devices from unlawful processing or unauthorised access. Encryption is also used to protect information that is in transit.
We also use the anonymisation of personal data wherever deemed prudent to ensure the rights of the individual are fully protected and observed.
In line with these principles, we are committed to the use both encryption and anonymisation as a risk management tool alongside existing systems, to protect the company from accidental loss, as well as from the damage or destruction of data or personal information.

Activities that are prohibited

Unless otherwise noted or informed, employees are strictly forbidden from using company equipment, tools or systems for any purpose unrelated to their role responsibilities, excluding any previously mentioned exceptions. This policy also relates to any relevant systems, tools or equipment belonging to a company client or partner.

Bearing that in mind, the following activities should be deemed forbidden with no exceptions:

  • Any unauthorised replication of copyrighted materials.
  • The violation of individual rights by way of the unnecessary collection, storage and processing of personal data or information.
  • The violation of rights of an individual or organisation protected under intellectual property law in any jurisdiction.
  • The use of any programme, command or interface designed to interfere with a user or corresponding user session.
  • The accessing of any data, user account or server for any purpose unrelated to the business function of an individual’s company role.
  • Issuing fraudulent product or service offers from a company account.
  • The allowed sharing or use of employee login credentials or company systems by anyone apart from the named individual.
  • The export of proprietary or confidential information as it relates to the company.
  • The export of any software or data that is in breach of regulation or the company’s data security policy.
  • Knowingly causing a network disruption or security breach.
  • An employee is not allowed to access data that is not intended for them by logging into a system or gaining access to a confidential or limited-access account. The only exception to this rule is if the employee is granted access as part of a specific company project.

Please note that any violation of this policy can lead to disciplinary action, alongside legal action where deemed prudent or necessary.

Reporting security issues

If you encounter any incidents or issues relating to the security or protection of information or data, you must report this immediately to company management. Management will subsequently take and record any action deemed necessary to prevent damage or loss in relation to a security threat.

If necessary, it is the responsibility of company management to report relevant incidents relating to a data breach or information security threat to regulators or the authorities. Under GDPR, it also falls upon management to contact the individuals involved in any breach or security threat.

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