Data Protection Policy

1) Aims of this policy

  1. Joju Ltd needs to keep certain information on its customers and suppliers in order to carry out its day to day operations, meet objectives and comply with legal obligations.
  2. Joju Ltd is committed to processing data in accordance with its responsibilities under the DPA 2018 and the GDPR.
  3. The aim of this policy is to ensure that everyone handling personal data whilst working for or with Joju Ltd is fully aware of the requirements of the DPA 2018 and the GDPR, and acts in accordance with data protection procedures.

2) Definitions

  1. GDPR: the European Union’s General Data Protection Regulation. Article 5 of the GDPR requires that personal data shall be:
    1. processed lawfully, fairly and in a transparent manner in relation to individuals;
    2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
    3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
    4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
    5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
    6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
  2. DPA 2018: UK Data Protection Act (2018)
  3. ICO: Information Commissioner’s Office, which is responsible for compliance with the UK Data Protection Act (2018).
  4. Responsible Person: the Joju Ltd employee with responsibility for Joju Ltd’s ongoing compliance with this policy. As of January 2019, this person is Chris JArdine, Joju Ltd’s Technical Director.
  5. Register of Systems: In relation to personal data, the Register of Systems is a record of 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, alteration, retrieval, consultation, use, disclosure, dissemination, restriction, erasure or destruction).
  6. Personal Data: Personal Data is data which relates to a living individual who can be identified either from that data alone or from that data and any other information in Joju Ltd’s possession, or which is likely to come into its possession. It also includes any expression of opinion about the individual and any information regarding the intentions of data processor towards the individual both singly and in combination with other information

3) General provisions

  1. This policy applies to all personal data processed by Joju Ltd.
  2. This policy covers staff, subcontractors, clients and suppliers.
  3. The Responsible Person will take responsibility for Joju Ltd’s ongoing compliance with this policy, including registration with the ICO as an organisation that processes personal data and payment of any fees to the ICO for registration or renewal.
  4. This policy is reviewed at least annually.

 4) Scope

  1. This Policy applies to the procedures used for collecting, maintaining, protecting, accessing, disclosing and disposing of personal data. This includes:
    1. Data held on any central computer server;
    2. Data held on any desk top personal computer or similar automatic device;
    3. Data held and processed by any bureau or sub-contractor;
    4. Data held on separate magnetic media such as floppy disks, cassettes, exchangeable discs, telecommunications devices, CD Roms and tapes;
    5. Computer output on paper, fiche or similar media;
    6. Manual data in structured files.

5) Lawful, fair and transparent processing

  1. To ensure its processing of data is lawful, fair and transparent, Joju Ltd maintains a Register of Systems.
  2. The Register of Systems is reviewed by the Responsible Person at least annually.
  3. Individuals have the right to access their personal data and any such requests made to Joju Ltd will be dealt with in a timely manner.

6) Lawful purposes

  1. All data processed by Joju Ltd is done on one of the following lawful bases: consent, contract or legitimate interests.
  2. The appropriate lawful basis is noted in Joju Ltd’s Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Joju Ltd’s systems.

7) Data minimisation

  1. The Responsible Person will ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  2. Joju Ltd processes only the following personal information:
    1. Personal contact information, in electronic and hard copy, including address, email address and telephone number.

8) Accuracy

  1. Joju Ltd will take reasonable steps to ensure personal data is accurate.
  2. Where necessary for the lawful basis on which data is processed, steps have been put in place to ensure that personal data is kept up to date.

9) Archiving / removal

  1. To ensure that personal data is kept for no longer than necessary, the Responsible Person has put in place an archiving policy for each area in which personal data is processed.
  2. The archiving policy considers what data should/must be retained, for how long, and why.
  3. The archiving policy is reviewed annually.

10) Security

  1. The Responsible Person will ensure that personal data is stored securely either using modern software that is kept up-to-date and is password-protected, or, if paper-based, in a locked filing cabinet.
  2. Access to personal data is limited to personnel who need access and appropriate security is in place to avoid unauthorised sharing of information.
  3. When personal data is deleted, this is done safely such that the data is irrecoverable.
  4. Appropriate back-up and disaster recovery solutions are in place.

11) Breach

  1. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Joju Ltd will promptly assess the risk to people’s rights and freedoms and, if appropriate, report this breach to the ICO.

12) Publication

  1. This Policy is publicly available on the Joju Ltd website:
  2. This Policy is explained to employees when they join Joju Ltd or when the Policy changes.