Data Protection Policies

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Data Protection policy

  •  House of Nature safaris needs to gather and use certain information about individuals.
  • 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.

The Data Protection Act 2019 (the “Act”) came into force on 25th November describes how organizations — including House of Nature Safaris— 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.

Policy Scope

This policy applies to:

  • The head office of House Of Nature Safaris
  • All branches of House Of Nature Safaris
  • All staff and volunteers of House Of Nature Safaris
  • All contractors, suppliers and other people working on behalf of House Of Nature Safaris

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of The Data Protection Act 2019 (the “Act”). This can include:

Names of individuals

  • Postal addresses
  • Email addresses
  • Telephone numbers
Data protection risks

This policy helps to protect House of Nature Safaris 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.
Responsibilities

Everyone who works for or with House of Nature Safaris 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 is ultimately responsible for ensuring that House of Nature Safaris meets its legal obligations.
  • The [data protection officer], is responsible for:
    o Keeping the board updated about data protection responsibilities, risks and issues.
    o Reviewing all data protection procedures and related policies, in line with an agreed schedule.
    o Arranging data protection training and advice for the people covered by this policy.
    o Handling data protection questions from staff and anyone else covered by this policy.
    o Dealing with requests from individuals to see the data House of Nature Safaris holds about them (also called ‘subject access requests’).
    o Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
     The [IT manager], is responsible for:
    o Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
    o Performing regular checks and scans to ensure security hardware and software is functioning properly.
    o Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
  • The [marketing manager], is responsible for:
    o Approving any data protection statements attached to communications such as emails and letters.
    o Addressing any data protection queries from journalists or media outlets like newspapers.
    o 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 are those who need it for their work.

  • Data is shared informally. When access to confidential information is required, employees can request it from their line managers.
  • House of Nature Safaris provides training to all employees to help them understand their responsibilities when handling data.
  • Employees keep all data secure, by taking sensible precautions and following the guidelines below.
  • In particular, strong passwords are used and are never shared.
  • Personal data is never disclosed to unauthorized people, either within the company or externally.
  • Data should is regularly reviewed and updated if it is found to be out of date. If no longer required, it is deleted and disposed of.
  • Employees request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
Data use

Personal data is of no value to House of Nature Safaris 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, our employees ensure the screens of their computers are always locked when left unattended.
  • Personal data is not shared informally. In particular, it is sent by email, as this form of communication is not secure.
  • We encrypt data before being transferring electronically. The IT manager can explain how to send data to authorized external contacts.
Data storage

These rules describe how and where data is safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
Data stored on paper, is 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 is kept in a locked drawer or filing cabinet.
  • Our Employees make sure paper and printouts are not left where unauthorized people could see them, like on a printer.
  • Unused Data printouts are shredded and disposed of securely when no longer required.
    Data stored electronically, is protected from unauthorized access, accidental deletion and malicious hacking attempts:
  • Data is protected by strong passwords that we change regularly (usually monthly) and never shared between employees.
  • If data is stored on removable media (like external storage media), these we keep locked away securely when not being used.
  • Data is stored in designated drives and servers, and only be uploaded to our Google Drive
  • Our Emails & Web Servers containing sensitive communication between our clients are sited in a secure location, away from general office space.( The Chancery data center, Nairobi, Kenya)
  • Data is backed up frequently. Those backups are tested regularly, in line with the company’s standard backup procedures.(normally after every change to the data)
  • Data is rarely saved directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing are protected by approved security software and a firewall.
    Machines in the office have Kaspersky antivirus software installed.
    The office Network is Protected by in-built FW on the router that does traffic filtering.
    Additional Emails Security is done by Mail cleaner-Antispam Filter Software
    Regular updates of Our Digital Devices are done regularly
Data accuracy

The law requires House of Nature safaris 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 House of Nature safaris 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 is held in as few places as necessary. Staff do not create any unnecessary additional data sets.
  • Staff take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they contact us.
  • Our Customer makes it easy for data subjects to update the information House of Nature safaris holds about them. For instance, via the company website – https://houseofnaturesafaris.com/
  • Data is updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, we remove it from the database.
  • Our marketing manager ensures marketing databases are checked against industry suppression files every six months.
Subject access requests
  1. Right to be informed

The right to information allows individuals (data subjects) to know what personal data is collected about them, why the data is collected, who is collecting data, for how long data is collected, how they can file a complaint, and if there is data sharing involved.

 

House Of Nature Safaris is obligated to provide information about:

  • Controller’s information and contact details
  • Purpose of data processing
  • Legal basis for personal data processing
  • Third party details
  • Data retention period
  • Rights granted to HONS under the data protection law
  • Right to file a complaint
  • Whether the provision of personal data is a statutory or contractual requirement
  • Whether the individual is obligated to provide the personal data

 

All of this information should be conveyed using straightforward and easily understandable language.

 

  1. Right of access

Individuals have a right to submit access requests and obtain information from us about whether their personal information is being processed. HONS is obligated to provide a copy of personal data they have about the individual and additional information, including:

 

  • The purpose of the processing
  • What categories of personal data are they processing
  • With whom the data is shared (third countries or international organizations)
  • How long will the organization keep the data (data retention period)
  • Information about their GDPR rights (right to rectification, right to erasure, and restriction of processing)
  • Information about automated decision-making, including profiling
  • Source of collected data (if the data is not collected from the individual)

 

  1. Right to rectification

The right to rectification allows the individuals to ask the organization to update any inaccurate or incomplete data they have on them.

If the organization confirms the data is inaccurate, the legal deadline to respond to a request is one month. Upon the request, the organization should ensure that the data is indeed inaccurate and rectify it.

This right sets new operational challenges for organizations since rectifying one data set can have broader consequences on the entire database.

 

  1. Right to be forgotten

The right to be forgotten is also known as the right to erasure. This right allows individuals to ask for their personal data to be deleted if:

 

  • Personal data is no longer necessary
  • Individual withdraws consent
  • Personal data is unlawfully processed
  • Individual objects to the processing, and the data controller has no reason to continue processing
  • Data erasure is necessary for compliance with a legal obligation

 

HONS informs any third parties that received the shared data and asks them to delete it unless it can prove that the request would require a disproportionate effort or would be impossible.

 

  1. Right to restrict processing

Individuals can request that an HONS limit how it uses its personal data, although we are not automatically required to delete it.

 

However, we have to refrain from processing in certain situations:

  • Data is inaccurate (during the verification process)
  • Processing is unlawful, but the individual does not want the data to be erased and requests restriction (which is different from the right to be erased)
  • HNS no longer needs data, but the individual wants the data to be preserved so the legal claim can be exercised
  • HNS is taking measures to verify the data erasure request

 

Once the data is restricted, HONS is not allowed to process it unless we have consent; we need it for legal claims or to protect the rights of other individuals.

 

  1. Right to data portability

Data portability is one of the novelties among data subject rights. It allows individuals to obtain personal data they have previously provided to us in a structured, commonly used, and machine-readable format.

Individuals can also request that their data be transferred directly to another organization.

However, it can only be applied to the data that an individual has provided to the HNS by consent or contract and if the processing is automated.

This also applies to data related to the individual’s behavior and may include search inquiries, location data, website history, and more.

 

  1. Right to object to processing

The right to object allows individuals to object to processing personal data at any time, in certain situations, and it will depend on the purpose of processing and the lawful base for processing.

Individuals can also object to data processing based on legitimate interests or tasks in the public interest.

 

  1. Rights in relation to automated decision-making and profiling

The GDPR introduced strict rules when it comes to the processing of personal data that is done without human involvement.

This encompasses different types of profiling, such as assessing individual performance at work, economic status, health, personal preferences, interests, reliability, behavior, or location, if it produces a legal effect that significantly affects them.

However, it will not apply if the processing is necessary for the performance of a contract, if it is authorized by the law, or if the processing is based on explicit consent.

 

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

Subject access requests from individuals are made by email, addressed to the data controller at [dpo@houseofnaturesafaris.com]. 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, House of Nature Safaris 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

House of Nature Safaris 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.
[This is available on request. A version of this statement is also available on the company’s website.]

Data Breach Policy and Procedures

House of Nature Safaris has implemented the following procedures to follow in the event of a data breach involving personally identifying information (PII) or other confidential information maintained on personal computers, agency networks, or internet programs used by staff and volunteers.

  • All data breaches of personal data must be reported internally and documented by the Data Protection Officer (DPO). The report can be made by every employee and every processor. The report can also be made by an external contact or by an employee of House of Nature Safaris. The report must be sent out directly and by telephone to the DPO and it must be in writing. Our DPO reports the data breach, if necessary, to the Personal Data Authority.
  • The DPO assess whether the infringement “can be reasonably assumed to lead to a significant risk of loss or unlawful processing, which adversely affects the privacy of the parties related.” If this is not the case, then the DPO will carry out the following actions:
    1. Inform the Managing Director of House of Nature Safaris by phone;
    2. Inform the manager of specific department officer by phone;
    3. During office hours: directly convene the Data Breach Response team, consisting of: The DPO, Managing Director, manager responsible for the department where the breach was found, and a member of the controlling team. The DPO is responsible for reporting.
Other Policies

CONTACT US/ FURTHER INFORMATION

If you have any queries at all in relation to your personal data and how we protect your data rights, please contact out Data Protection Officer through dpo@houseofnaturesafaris.com. You are also welcome to visit our offices.

This is our commitment to take into account social, ethical and environmental considerations with regards to our products and supply chains and when managing our relationships with suppliers.

This a statement describing the steps our organization has taken during the financial year to deal with modern slavery risks in your supply chains and your own business.

The Equal Opportunity Policy emphasizes fairness and diversity in the workplace. It ensures that all employment aspects, from hiring to termination, are free from discrimination based on protected characteristics. The policy promotes an environment where everyone’s rights are respected and valued.

The Policy is guided by the existing laws on Occupational Safety and Health (OSH), Work Injury Benefits and other relevant regional and International Labour Standards without any exemption.