Data Protection Policy

Introduction
IMIT Douala, Cameroon needs to gather and use certain information about individuals who can include students, trainers /lecturers, suppliers, business contacts, employees and other people IMIT has a relationship with or may need to contact.

This policy describes how personal data must be collected, handled and stored to meet the data protection standards of IMIT, and to comply with applicable laws.

Why this policy exists
This data protection policy ensures that IMT:

* Complies with data protection law and related regulations, and follow good practice
* Protects the rights of staff, students, customers and partners
* Is open about how it stores and processes individuals’ data
* Protects itself from the risks of a data breach

Guidance
Data protection at IMIT shall be guided by the legal framework of Cameroon and all international laws and conventions ratified by Cameroon and relevant to the protection of personal data. Data protection at IMIT is underpinned by the following important

principles:
Personal data must be:

– Be obtained only for specific, lawful purposes
– Processed in accordance with the rights of data subjects
– Be processed fairly and lawfully
– Be adequate, relevant and not excessive
– Be accurate and kept up to date
– Be protected in appropriate ways
– Not be held for any longer than necessary

Scope
This policy applies to:

* The head office of IMIT

* All branches of IMIT

* All staff and volunteers of IMIT

* All students of IMIT

* All contractors, suppliers and other people working on behalf of IMIT

It applies to all data that the school holds relating to identifiable individuals, even if that information technically falls outside of the applicable data protection laws.

This can include:

* Names of individuals

* Postal addresses

* Email addresses

* Telephone numbers

* any other information relating to individuals

Responsibilities
Everyone who works for or with IMIT has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, the following people have key areas of responsibility

* The School management board is ultimately responsible for ensuring that IMIT meets its legal obligations.
* The Director of IMIT
* The Chief Executive Assistant is responsible for:
– Keeping the board updated about data protection responsibilities, risks and issues.
– Reviewing all data protection procedures and related policies, in line with an agreed schedule.
– Arranging data protection training and advice for the people covered by this policy.
– Handling data protection questions from staff and anyone else covered by this policy.
– Dealing with requests from individuals to see the data IMIT holds about them.
– Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

* The IT manager, is responsible for:

– Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
– Performing regular checks and scans to ensure security hardware and software is functioning properly.
– Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

* All administrative staff are responsible for:
– Approving any data protection statements attached to communications such as emails and letters.
– Addressing any data protection queries from journalists or media outlets like newspapers.
– Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General staff guidelines

* 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. When access to confidential information is required, employees can request it from their line managers.
* IMIT 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 and following the guidelines below.
* In particular, strong passwords must be used and they should never be shared.
* Personal data should not be disclosed to unauthorised people, either within IMIT or externally.
* Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
* Employees should request help from their superior or the data the chief executive assistant if they are unsure about any aspect of data protection.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager. Data stored on paper, it shall be kept in a secure place where unauthorised people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
• Data printouts should be shredded and disposed of securely when no longer required.
• When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:Data should be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently. Those backups should be tested
  regularly, in line with the company’s standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data should be protected by Approved security software and a firewall.

Use of Data

Considering the risks associated with accessing and using data, IMIT emphasises the following measures to curb the risk of loss, corruption or theft of personal data:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Accuracy of Data

The law requires IMIT to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort IMIT should put into ensuring its accuracy. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• IMIT will make it easy for data subjects to update the information IMIT holds about them. For instance, via the company website.
• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Access to data by the subject of the data

All individuals who are the subject of personal data held by IMIT have the right to:

• Ask what information the school holds about them and why.
• Ask how to gain access to their personal information.
• Be informed how to keep their personal data up to date.
• Be informed how the school is meeting its data protection obligations.

Requests from individuals for access to their personal data should be made by email, addressed to the Administrative Assistant at info@imitpford.org or training@imitpford.org. The administrative assistant can supply a standard request form, although individuals do not have to use this.

The Administrative assistant will always verify the identity of anyone requesting access to such data before handing over any information.

Individuals may be charged 8,000XAF per subject access request. The administrative assistant will aim to provide the relevant data within 10 working days.

Disclosing data for other reasons

In certain circumstances, the Data Protection Acts allow personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, IMIT will disclose requested data. However, the administrative assistant will ensure the request is legitimate, seeking assistance from the school management board and from the school’s legal advisers where necessary.

Providing information
IMIT aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How the data is being used
• How to exercise their rights