INTRODUCTION

C.T. Antoniou & Co LLC (“CTA Law Firm”) needs to gather and use certain information about individuals.

These can include clients, associates, employees, business partners 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.

WHY THIS POLICY EXISTS

This data protection policy ensures CTA Law Firm:

1) Complies with data protection law and follow good practice;

2) Protects the rights of staff, clients and business partners;

3) Is open about how it stores and process individuals’ data;

4) Protects itself from the risks of a data breach.

DATA PROTECTION LAW

The Data Protection Act 1998 describes how organizations – including CTA Law Firm – 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 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;

8) Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.

PEOPLE, RISKS AND RESPONSIBILITIES

Policy Scope

This policy applies to:

1) The head office of CTA Law Firm;

2) All affiliated companies, branches, representative offices of CTA Law Firm;

3) All staff of CTA Law Firm;

4) All associates, business partners, and other people working with and on behalf of CTA Law Firm.

It applies to all data that CTA Law Firm holds relating to identify individuals, such as:

1) Personal details: (i) names of individuals, (ii) residential addresses, (iii) business addresses, (iv) email addresses, (v) telephone numbers, (vi) nationality, (vii) passport number, (viii) identity card number, (ix) detailed description of occupation, (x) utility bill/s, (xi) bank reference letter/s, (xii) bank statement/s, (xiii) Curriculum Vitae, (xiv) information about your criminal record if it’s not clean.

2) Financial information: (i) source of wealth, (ii) size of wealth, (iii) total annual income, (iv) country of tax residence, (v) tax identification number.

3) Payment information: (i) bank account details, (ii) name of accountholder, (iii) SWIFT details, (iv) IBAN details, (v) payment amount/s, (vi) payment date/s, (vii) records of payments, (viii) records of invoices.

4) Any information about your kind self that is publicly available.

5) Consent: any express consent given to us, for the processing of your details, and/or for obtaining any articles, newsletters, updates in relation to the services, legal and financial updates.

6) Business partners data: details about your company and/or organization and/or your kind self to establish our relationship, such as licenses of the company and/or organization, corporate documents of the company and/or organization, personal details of the persons authorized to provide us with instructions or the persons that we provide with instructions.

Data Protection Risks

This policy helps to protect CTA Law Firm from some very real data security risks, including:

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

Responsibilities

Everyone who works for or with CTA Law Firm 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:

a) The board of directors is ultimately responsible for ensuring that CTA Law Firm meets its legal obligations.

b) The Data Protection Officer, Christiana Antoniou, 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 that CTA Law Firm 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.

c) 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.

d) The marketing manager, Theo Antoniou,is 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.
CTA Law Firm 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 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.
If data is stored on removable media (like a CD or DVD or USB or external disk), 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 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.

DATA USE

How do we use your data

1) Before accepting any client we require certain information to be in compliance with the anti-money laundering laws and regulations. This information is evaluated and if the client is approved by the Compliance officer, we proceed with the preparation of the onboarding documentation, by using the information provided.

2) Such information is kept to our records upon the acceptance of the client as provided by the anti-money laundering laws and regulations and by GDPR.

3) In the case where you instruct us to proceed with any legal and/or administrative and/or corporate and/or trust request, task or project and prepare or review contracts, letters, application forms or any other documentation that might be requested from time to time.

4) Upon instructions for any legal proceeding or claim or court application, exercising and defending legal rights/claims, for any form/s and/or application/s and/or documents addressed to the Authorities of the Republic of Cyprus.

5) To comply and/or fulfill any regulatory and/or legal obligations.

6) For communication purposes either by email or via telephone or via internet communication tools or by sending documents to your residential or business address by post or by courier service provided that your express consent has been obtained.

DATA ACCURACY

The law requires CTA Law Frim 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 CTA Law Firm 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 client’s details when they call.
CTA Law Firm, will make it easy for data subjects to update the information of CTA Law Firm holds about them. For instance, via the company website.
Data should be updated as inaccuracies are discovered. For instance, if a client 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.
We kindly ask you to provide us with any changes on your personal details or the information provided contacting us by email. We do not undertake any responsibility for any losses arising from any inaccuracy, deficiency or incompleteness on the personal data that you provided to us.

ACCESS TO PERSONAL DATA

All individuals who are the subject of personal data held by CTA Law Firm 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.
Any client may request such information and the controller should provide this information to the client.

The right of access by the data subject can be exercised by email, addressed to the data controller at [email protected] The data controller will aim to provide the relevant data within 14 days.

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, CTA Law Firm will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board where necessary.

Moreover, we may disclose information to our business partners, trusted third parties and/or our associates or subsidiaries or affiliated companies to proceed with your project and/or task and/or legal advice and/or any other legal or administrative request that you may address to us and/or law enforcement bodies and regulators.

PROVIDING INFORMATION

CTA Law Firm, 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.