PRIVACY POLICY

Titan Impex needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees, and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled, and stored to meet the company's data protection and privacy standards — and to comply with the law Data Protection Act 2019.

Definitions

Data Controller - means a natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purpose and means of processing of personal data.

Data Processor - means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the data controller.

Data Protection Officer - Person appointed by the Data controller to oversee a company's data protection strategy and its implementation to ensure compliance with the Data Compliance Act 2019.

Why this policy exists

This data protection policy ensures Titan Impex:

• complies with data protection law and follow good practice
• Protects the rights of staff, customers, and partners
• Is open about how it stores and processes individuals' data
• Protects itself from the risks of a data breach

The Data Protection Act 2019 describes how organisations including Titan Impex must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. The Data Protection Act 2019 is underpinned by 8 important principles. These say that personal data must:

1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant, and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Be processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside Kenya unless there is proof of adequate data protection safeguards or consent from the data subject

Policy Scope

This policy applies to:

• The head office of Titan Impex
• All branches of Titan Impex
• All staff and volunteers of Titan Impex
• All contractors, suppliers and other people working on behalf of Titan Impex

It applies to all data that the company holds relating to identifiable individuals, including:

• Names of individuals
• Postal addresses
• Email addresses
• National Identity Numbers
• Telephone numbers
• Plus, any other information relating to individuals

Data Protection Risks

This policy helps to protect Titan Impex from data security risks, including:

• Breaches of confidentiality
• Failing to offer choice
• Reputational damage

• The only people able to access data covered by this policy should be those who need it for their work
• Data should not be shared informally
• Titan Impex will provide training to all employees to help them understand their responsibilities when handling data
• Employees should keep all data secure, by taking sensible precautions
• Strong passwords must be used, and they should never be shared
• Personal data should not be disclosed to unauthorised people
• Data should be regularly reviewed and updated if it is found to be out of date

Paper Storage

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it:

• Paper or files should be kept in a locked drawer or filing cabinet when not required
• Employees should make sure paper and printouts are not left where unauthorised people could see them
• All documents held in physical format should be backed up on the share point
• Data printouts should be shredded and disposed of securely when no longer required

Electronic Storage

When data is stored electronically, it must be protected from unauthorised access:

• Data should be protected by strong passwords that are changed regularly
• If data is stored on removable media, these should be kept locked away securely
• Data should only be stored on designated drives and servers
• Servers containing personal data should be sited in a secure location
• Data should be backed up frequently and tested regularly
• Data should never be saved directly to laptops or mobile devices
• All servers and computers containing data should be protected by approved security software

When working with personal data, employees should ensure:

• Computer screens are always locked when left unattended
• Personal data should not be shared informally
• Data must be encrypted before being transferred electronically
• Personal data should never be transferred outside of Titan Impex
• Employees should not save copies of personal data to their own computers

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the informed consent of the data subject. Under these circumstances, Titan Impex will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company's legal advisers where necessary.