Data protection principles and privacy policy

Content and overview

  • Policy prepared by:                               Zalman Porte
  • Policy became operational on:               6/13/2022
  • Next review date:                                 6/13/2023    

Introduction

Norfa Inc. needs to gather and use certain information about individuals who are making purchases online across different sales channels.

These can include customers, suppliers, business contacts, employees and other people the organization 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 standards — and to comply with the law.

Norfa Inc. maintains physical, administrative, and technical safeguards, and other security measures (i) to maintain the security and confidentiality of Personal Information accessed, collected, used, stored, or transmitted by a Norfa Inc., and (ii) to protect that information from known or reasonably anticipated threats or hazards to its security and integrity, accidental loss, alteration, disclosure, and all other unlawful forms of processing.

Why this policy exists.

This data protection policy ensures Norfa Inc.:

  • 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

Data protection principles

The Data Protection principles is underpinned by eight 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. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways

 

People, risks, and responsibilities

Policy scope

This policy applies to:

  • The head office of Norfa Inc.
  • All branches of Norfa Inc.
  • All staff and volunteers of Norfa Inc.
  • All contractors, suppliers and other people working on behalf of Norfa Inc.

 

It applies to all data that the company holds relating to identifiable individuals. 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 Norfa Inc.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, these people have key areas of responsibility:

  • The board of directors or director is ultimately responsible for ensuring that [Norfa Inc. meets its legal obligations.
  • The data protection officer is assigned by a president and 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 Norfa Inc. holds about them (also called ‘subject access requests’).
    • 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.

 Data protection risks

This policy helps to protect Norfa Inc. from some very real data security risks, including:

  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
  • Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

 

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.
  • Norfa Inc. 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 and changed each 3 months
  • Personal data should not be disclosed to unauthorized people, either within the company 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 line manager or the data protection officer 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 or data controller.

When data is stored on paper, it should be kept in a secure place where unauthorized 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 unauthorized 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 unauthorized access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared between employees.
  • Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing services.
  • 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.
  • All data should be encrypted.
  • Access to data is restricted from any unauthorized devices including personal employee’s devices.

 

Data use

Personal data is of no value to Norfa Inc. unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption, or theft:

  • 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. It should never be sent by email or other internal/external communication platform, as these forms of communication are not secure.
  • Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorized external contacts.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.


Personal information and data collection from third party marketplaces

Norfa Inc. collects personal customer’s information from third party marketplaces.  This section can be updated depending on the sales channels/ marketplaces Norfa Inc. sells on.

Amazon
Norfa Inc. (seller name – Parma Home) as an Amazon Seller uses Selling Partner API and Amazon Marketplace Web Service.  For the order processing and fulfilment and processing purpose
Norfa Inc. collects from Amazon customer’s Personal Identifiable Information (PII) which includes, but is not limited to, a Customer or Seller's name, address, e-mail address, phone number, gift message content, survey responses, payment details, purchases, cookies, digital fingerprint (e.g., browser, user device), IP Address, geo-location, or Internet-connected device product identifier.  Information is stored as long as necessary to proceed and fulfil the order but not longer than 30 days.

While managing Personal Identifiable Information (PII)  Norfa Inc. comply with the following requirements and principles:

Network Protection.  Access to all information and database provided for authorized IP address only and authorized internal users.

Access Management.   Each developer has own unique credentials to access personal information on the Amazon order level. All access as well as access attempts and anomalous usage pattern are logged.  No direct access to the database is provided to any user.

Security Incidents. Any detected security incidents must be reported to Amazon within 24 hours.  All incidents must be handled bases on Incident Response plan.

Request for Deletion or Return.
Norfa Inc.  on Amazon's request must promptly (but within no more than 72 hours after Amazon's request), permanently, and securely delete (in accordance with industry-standard sanitization processes, e.g., NIST 800-88) or return Amazon Information upon and in accordance with Amazon's notice requiring deletion and/or return. Norfa Inc.  must also permanently and securely delete all live (online or network accessible) instances of Amazon Information within 90 days after Amazon's notice. If requested by Amazon, the Norfa Inc.   will certify in writing that all Amazon Information has been securely destroyed.

Data Retention and Recovery. Norfa Inc. retains PII only for the purpose of, and as long as is necessary to proceed and fulfil orders (no longer than 30 days after order shipment), or to calculate/remit taxes. If Norfa Inc.is required by law to retain archival copies of PII for tax or similar regulatory purposes, this archived Amazon Information must be stored as a "cold" or offline (e.g., not available for immediate or interactive use) backup stored in a physically secure facility, and all archived data on backup media must be encrypted. In the event that PII is lost, you must be able to recover all PII lost (i.e., the data is erased or unavailable for processing due to system crash or ransomware).

Data Governance. A record of data processing activities such as specific data fields and how they are collected, processed, stored, used, shared, and disposed for all PII Information is maintained to establish accountability and compliance with regulations.

Encryption and Storage. All PII is encrypted at a rest using RSA 2048-bit key size (or higher) or AES-128 encryption algorithm . The cryptographic materials (e.g., encryption/decryption keys) and cryptographic capabilities (e.g., daemons implementing virtual Trusted Platform Modules and providing encryption/decryption APIs) used for encryption of PII at rest are only accessible to the Developer's processes and services. PII cannot be stored on any removable media (e.g., USB) or unsecured public cloud applications (e.g., public links made available through Google Drive). Any printed documents containing PII must securely disposed.

Least Privilege Principle. Fine-grained access control mechanisms is implemented to allow granting rights to any party using the Application (e.g., access to a specific set of data at its custody) and the Application's operators (e.g., access to specific configuration and maintenance APIs such as kill switches) following the principle of least privilege. Application sections or features that vend PII are protected under a unique access role, and access is granted on a "need-to-know" basis.

Logging and Monitoring. In order to detect security-related events (e.g., access and authorization, intrusion attempts, configuration changes) to Applications and systems we gather all logs. This logging mechanism is implemented on all channels (e.g., service APIs, storage-layer APIs, administrative dashboards) providing access to Amazon Information. All logs have access controls to prevent any unauthorized access and tampering throughout their lifecycle. Logs themselves does not contains PII and are retained for at least 90 days for reference in the case of a Security Incident. Logs and all system activities are monitored regularly to trigger investigative alarms on suspicious actions (e.g., multiple unauthorized calls, unexpected request rate and data retrieval volume, and access to canary data records).

Data accuracy

The data protection policies require Norfa Inc.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 Norfa Inc. 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.
  • Norfa Inc.will make it easy for data subjects to update the information Norfa Inc.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.

 Subject access requests

All individuals who are the subject of personal data held by Norfa Inc.are entitled to:

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

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at dataprotection@norfahome.com. The data controller can supply a standard request form, although individuals do not have to use this.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

 Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Norfa Inc.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.

 Providing information

Norfa Inc. 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

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.