General Data Protection Regulation (GDPR) Policy

1. Data Protection Principles

Article 5 of the GDPR requires that personal data shall be:

• Processed lawfully, fairly, and in a transparent manner in relation to individuals;
• Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
• Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and, where necessary, kept up to date;
• 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;
• Processed in a manner that ensures appropriate security of the personal data.

2. General Provisions

• This policy applies to all personal data processed by Kiwi Hosting.
• The Responsible Person shall take responsibility for Kiwi Hosting’s ongoing compliance with this policy.
• This policy shall be reviewed at least annually.
• Kiwi Hosting shall register with the Information Commissioner’s Office as an organisation that processes personal data.

3. Lawful, Fair, and Transparent Processing

• Kiwi Hosting shall maintain a Register of Systems to ensure its processing of data is lawful, fair, and transparent.
• The Register of Systems shall be reviewed at least annually.
• Individuals have the right to access their personal data, and any such requests made to Kiwi Hosting shall be dealt with in a timely manner.

4. Lawful Purposes

• All data processed by Kiwi Hosting must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task, or legitimate interests.
• Kiwi Hosting shall note the appropriate lawful basis in the Register of Systems.
• Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
• 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 the systems.

5. Data Minimisation

• Kiwi Hosting shall ensure that personal data are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.

6. Accuracy

• Kiwi Hosting shall take reasonable steps to ensure personal data is accurate.
• Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / Removal

• To ensure that personal data is kept for no longer than necessary, Kiwi Hosting shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
• The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security

• Kiwi Hosting shall ensure that personal data is stored securely using modern software that is kept up-to-date.
• Access to personal data shall be limited to personnel who need access, and appropriate security measures should be in place to avoid unauthorised sharing of information.
• When personal data is deleted, this should be done safely such that the data is irrecoverable.
• Appropriate backup and disaster recovery solutions shall be in place.