If you require any more information or have any questions about our privacy policy, please feel free to contact us by email at
At www.hooopcyber.com (HOOP Cyber) the privacy of our visitors is of extreme importance to us. This privacy policy document outlines the types of personal information is received and collected by www.hoopcyber.com and how it is used.
Log files
Like many other Web sites, www.hoopcyber.com makes use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and number of clicks to analyse trends, administer the site, track user’s movement around the site, and gather demographic information. IP addresses, and other such information are not linked to any information that is personally identifiable.
Cookies
HOOP Cyber does use cookies to store information about visitor’s preferences, record user-specific information on which pages the user access or visit, customise Web page content based on visitors browser type or other information that the visitor sends via their browser.
If you wish to disable cookies, you may do so through your individual browser options. More detailed information about cookie management with specific web browsers can be found at the browsers’ respective websites.
Information collection
General. When you visit the Site, you can browse without submitting any personal information about yourself. We will, however, receive and store some non-personally identifiable information about you, as described below. In order to participate in certain functionalities, you may be asked to provide personally identifiable information. Personally identifiable information is information that can identify you, including, for example, your name or email address.
Communications; Email Address Collection. In order to receive certain communications from us, such as responses to user inquiries, you will be required to submit your email address to us. You may also provide your email address to us in order to receive news even if you do not sign up for an account. Any non-Service related email you receive from us will include an unsubscribe link that will allow you to opt-out of receiving future emails.
User Content. The Service may allow you to post or submit comments or other information, such as in response to our content (www.cybersecurityassociation.co.uk/articles) (“User Content”). We may use User Content to improve the Service and we may save User Content or other content you post indefinitely.
Automatically Collected Information. Similar to other websites, we may collect some information automatically from you and store it in log files. This collection may include, but is not limited to: your domain name and host for Internet access, the Internet address of the site from which you came, the date and time of your access, your computer’s IP address and information about its operating system, browser, and host, the date and time you access the Service and the pages you visit. We collect this non-identifying information in order to help diagnose problems and to administer the Service. We also use it to help identify you and to gather broad demographic information. We may automatically collect information using various mechanisms, including but not limited to cookies and pixels.
A “cookie” is a small text file that is stored on a computer for record-keeping purposes. We use cookies for analysing trends, site administration, tracking user movement, and to gather demographic information from our base as a whole. Some cookies remain on your computer until you delete them. Others, like session ID cookies, expire when you close your browser. You may set your browser setting to attempt to reject cookies and you may still use the Service, however, certain features of the Service may not be available if your browser does not accept cookies. See “Do-Not Track Settings” below for more information on how use of the Service may or may not be affected by your browser settings. We do not control the use of cookies by third parties. Also see “Third Party Analytics Providers” below.
“Pixels” are tiny graphics with a unique identifier that are used to track the online movements of web users. Unlike cookies, which are stored on a computer’s hard drive, pixels are small graphics that are about the size of the period at the end of the sentence that are embedded invisibly on web pages or in HTML-based emails. Our third-party analytics providers may place pixels on the Site that track what other websites you visit (both before and after visiting the Site). Our third-party analytics providers use information obtained from pixels to help us improve our business and the Service. We do not control the use of pixels by third parties.
Third Party Analytics Providers. We use third parties to help us operate and improve the Service. In doing so, we may share with these third parties non-personally identifiable information about users’ use of the Service. These third-party providers also use cookies. We use third party analytics providers, such as Google Analytics, to provide us with general demographic and interest-level information about our users and to help create a better user experience. We do not control information collected by third parties and are not responsible for their use of that information.
Google Analytics uses cookies and pixels in order to collect demographic and interest-level information and usage information from users that visit the Service, including but not limited to information about the pages where users enter and exit the Service and what pages users view on the Service, time spent, browser, operating system, and IP address. Cookies and pixels allow Google to recognise a user when a user visits the Service and when the user visits other websites. Google uses the information it collects from the Service and other websites to share with us and other website operators’ information about users including, but not limited to, age range, gender, geographic regions, general interests, and details about devices used to visit websites and purchase items. We take reasonable measures to prevent linking of information we receive from Google with any of your personally identifiable information. For more information regarding Google’s use of cookies and collection and use of information see the Google Privacy Policy. To opt out of Google Analytics, please visit the Google Analytics Opt-Out Page to learn about opting out and installing the appropriate browser add-on.
“Do Not Track” Settings. Because we track website usage information as described above, your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of certain information. The only way to completely “opt out” of the collection of information through cookies or other tracking technologies is to actively manage the settings on your browser to delete and disable cookies and other tracking/recording tools. However, getting a “Do Not Track” signal to work as you might want is difficult. Using browsers as an example, not all tracking technologies can be controlled by browsers; unique aspects of your browser might be recognisable even if you disable a tracking technology; not all settings will necessarily last or be effective; even if a setting is effective for one purpose, data still may be collected for another; and even if one website observes a “Do Not Track” signal, that website may not be able to control other websites.
Linked Sites. The Site may contain links to third party websites (“Linked Sites”), including social media features such as Facebook, LinkedIn, or Twitter buttons. We are not responsible for the privacy practices or content of any Linked Sites and Linked Sites may collect personally identifiable information from you that is not subject to our control. The data collection practices of Linked Sites will be governed by that site’s privacy policy.
What do we use your information for?
Any of the information we collect from you may be used in one of the following ways:
To personalise your experience (your information helps us to better respond to your individual needs) To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you) To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs) To send periodic emails The email address you provide may be used to send you information, respond to inquiries, and/or other requests or questions.
Do we use cookies?
Yes – Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognise your browser and capture and remember certain information
We use cookies to understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
Do we disclose any information to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Online Privacy Policy Only
This online privacy policy applies only to information collected through our website and not to information collected offline.
Your Consent
By using our site, you consent to the above terms of our privacy policy.
HOOP Cyber is committed to conducting its business with the highest ethical standards and in full compliance with all applicable laws and regulations, including the Bribery Act 2010 (the Act). This Anti-Bribery and Corruption (ABC) Policy outlines our zero-tolerance approach to bribery and corruption and establishes clear procedures and training to ensure all employees and associated persons understand their obligations.
Our Commitment
HOOP Cyber has a zero-tolerance policy for bribery and corruption in all its forms. We are committed to:
Acting with integrity and transparency in all business dealings.
Competing fairly and ethically for business opportunities.
Maintaining a culture of open communication and reporting concerns.
Fulfilling our legal obligations under the Bribery Act 2010 and other relevant legislation.
What is Bribery and Corruption?
Bribery is the offering, promising, giving, requesting, agreeing to receive, or accepting of an undue advantage (financial or otherwise) to:
Influence the outcome of a business decision.
Obtain or retain an advantage in the conduct of business.
Corruption is the misuse of entrusted power for personal gain. It can encompass various forms, including:
Fraudulent schemes.
Collusion with competitors.
Improper use of confidential information.
Improper influence in the awarding of contracts.
Who is Covered by this Policy?
This policy applies to all employees, directors, officers, agents, consultants, contractors, suppliers, joint venture partners, and other third parties acting on behalf of HOOP Cyber.
Red Flags and High-Risk Situations
Certain situations can increase the risk of bribery and corruption. These include:
Dealing with government officials or public bodies.
Operating in high-risk jurisdictions with weak anti-bribery laws.
Engaging in large or complex transactions.
Offering or receiving gifts and hospitality.
Making facilitation payments (payments to expedite routine government actions).
Dealing with third parties with a history of corruption.
Responsibilities
Management:
Implement and maintain this ABC Policy.
Conduct risk assessments to identify and mitigate bribery and corruption risks.
Provide adequate training and guidance to all employees and associated persons.
Establish and maintain a whistleblowing hotline for reporting concerns.
Investigate all reported violations of this policy effectively and fairly.
Take appropriate disciplinary action against those who breach this policy.
Employees and Associated Persons:
Become familiar with and comply with this ABC Policy and procedures.
Conduct business with integrity, honesty, and transparency.
Avoid situations that could create a conflict of interest.
Declare any gifts and hospitality received or offered.
Refuse to offer or accept bribes.
Report any suspected bribery or corruption to the appropriate authority.
Ask for clarification if unsure about the application of this policy.
Gifts and Hospitality
Offering and Receiving Gifts:
Employees and associated persons may offer or accept gifts and hospitality only if:
The value is reasonable and customary.
There is no expectation of receiving an advantage in return.
It will not create an obligation or compromise business judgment.
Prior Approval Required:
Approval from a supervisor must be sought before offering or accepting:
Gifts exceeding a predetermined reasonable value.
Cash or cash equivalents.
Gifts or hospitality that could create a perception of impropriety.
Record Keeping:
All gifts and hospitality offered or received must be declared and recorded with appropriate details.
Facilitation Payments
Facilitation Payments are Strictly Prohibited:
HOOP Cyber has a zero-tolerance policy for facilitation payments, which are small bribes used to expedite routine government actions like obtaining permits or licenses. Employees and associated persons must refuse to make or authorize facilitation payments under any circumstances.
Record Keeping and Due Diligence
Financial Records:
HOOP Cyber will maintain accurate and complete financial records of all business transactions. This includes recording details about gifts, travel, and entertainment expenses.
Third-Party Due Diligence:
Appropriate due diligence will be conducted on all third parties before entering into any business relationship. This includes assessing their anti-bribery and corruption policies and procedures.
Reporting Concerns
HOOP Cyber encourages open communication and maintains a whistleblowing hotline for employees.
HOOP Cyber is committed to the principle of equality of opportunity and diversity and recognises that employees, volunteers, members or service users should not experience discrimination on any grounds.
To promote equality and diversity in our organisation we will:
Encourage, value and manage diversity and to promote equality of opportunity in all areas of its work and structure, and will take positive action in the areas of employment and volunteering, representation, membership and service provision.
Recognise that many people in our society experience discrimination. It is our policy that no person or group of people should suffer oppression or lack or opportunity because of their gender, race, nationality, disability, sexuality, age, HIV status, class, geographical location, trades union activity, marital status, political activity or religious activity.
Believe that all forms of discrimination are unacceptable, regardless of whether there was any intention to discriminate or not.
Aims to provide an environment where all employees, volunteers, members and service users at all levels are valued and respected and where discrimination and harassment are not tolerated.
Recognise that The Equality Act 2010 identifies people who have an attribute defined as a ‘protected characteristic’ and prohibits discrimination against them by reason of that attribute.
The characteristics that are protected by the Act are:
Disability
Age
Gender reassignment
Neurodiversity
Marriage and civil partnership
Pregnancy and maternity
Race
Religion or belief
Sex
Sexual orientation
Definitions
‘Equality’ means understanding and seeking to remove the different barriers to equal opportunities for different groups of people.
`Discrimination’ is acting unfairly against a group or individual through actions such as exclusion, verbal comment, denigration, harassment, victimisation, a failure to appreciate needs or the assumption of such needs without consultation.
The term `disability’ applies to a person who has a physical or mental impairment that has a substantial and long-term adverse effect on their ability to carry out their normal day-to-day activities.
`Race’ includes ethnic or national origins, colour or nationality.
The Equality Act 2010 is the statute replacing previous anti-discrimination laws. It applies to all organisations that provide a service to the public, sell goods or provide facilities, irrespective of whether they charge for them.
It is the responsibility of HOOP Cyber to implement this policy, and to review it annually.
HOOP Cyber has a duty to ensure that this policy is effective in ensuring equal opportunities and in preventing discrimination. They should draw the attention of a staff member or a member of the management committee to suspected discriminatory acts or practices or cases of bullying or harassment.
HOOP Cyber will ensure that the users of this policy are made aware of its contents and responsibilities by presenting it in a suitable form, offering an accessible copy where appropriate.
All trainers, facilitators and consultants contracted to work for [insert organisation name] will be required to support our Equality and Diversity policy.
Copies of this policy will be freely available to staff, volunteers, members and any other interested parties. A copy will be displayed in a prominent position in places where our activities are regularly carried out.
Training will be provided for employees, committee members and volunteers on cultural awareness, disability awareness and other subjects that will develop from equality and diversity.
Action we will take
We will:
Develop an organisational culture that positively values diversity
Achieve, wherever possible, a membership, committee membership and workforce that broadly reflects the local community in which we operate and is representative of all sections of society
Ensure that individuals are treated fairly in all aspects of their employment with Hoop Cyber.
Make it clear that intimidation, harassment and bullying will not be tolerated and may lead to disciplinary action
Ensure that all our services are provided in a way which promotes awareness of the rights and needs of the people who face discrimination and enables all people to have access to them
Encourage the development of skills and knowledge through training
Ensure that premises used in relation to our work are accessible and inviting for all members of the community
Challenge any discrimination or oppressive behaviour from and towards any members, volunteers, clients or agencies we work with
Work in a way that recognises peoples’ individual needs
Regularly evaluate this policy and seek feedback from those who are affected by it
1.1 HOOP Cyber’s core values are to act in a manner which is ethical, respectful, transparent, inclusive and fair, challenging, confident, collaborative and professional. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
1.2 HOOP Cyber has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
1.3 HOOP Cyber is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. The same high standards are expected from all of our contractors, suppliers and other business partners. Wherever practicable, HOOP Cyber will seek to include in our contracts with business partners specific prohibitions against the use of bonded, forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and expects that all suppliers will hold their own suppliers to the same high standards.
2. Scope of Policy
2.1 For the purposes of this Policy “staff” refers to all persons employed by HOOP Cyber or who conduct work for or on behalf of HOOP Cyber, including permanent, fixed term, and temporary staff, freelance and student workers (including work experience).
2.2 This policy does not form part of any employee’s contract of employment and we may amend it at any time.
3. Responsibility for Policy
3.1 This policy is adopted by HOOP Cyber which has overall responsibility for ensuring their employers and employees complies with its legal and ethical obligations. Simon Johnson, Managing Director of HOOP Cyber has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
3.2 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
4. Compliance with the Policy
4.1 You must ensure that you read, accept and comply with this policy.
4.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
4.3 You should notify your Line Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
4.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at any level of supply at the earliest possible stage.
4.5 If you believe or suspect a breach of this policy has occurred or that it may occur you should notify Line Manager as soon as possible.
4.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or with Kathryn Young, Share Holder.
4.7 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
If you believe that you have suffered any such treatment, you should inform your Line Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure which can be found at in your staff handbook.
4.8 You can also raise your concerns with any of the following; the Police (101), Stronger Together, Stop the Traffic, Migrant Helpline
5. Communication and awareness of this Policy.
5.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, will be provided as necessary.
5.2 HOOP Cyber’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
6. Breaches of this Policy
6.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
6.2 HOOP Cyber may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
NOTE: This Policy has been implemented by Simon Johnson, Managing Director.
HOOP Cyber is committed to the achievement of outstanding environmental performance and sustainable development of the natural and built environment for the benefit of present and future generations.
We are striving to ensure every aspect of our business incorporates the principles of sustainability. This means we will strive for sustainability in our roles as a planning and enforcement authority, major employer, land and property owner, provider of services, a significant purchaser within the local economy, leading grant-maker and facilitator of community initiatives.
HOOP Cyber recognises that managing the environmental impact of operations is essential. We are committed to reducing greenhouse gas emissions and adapting to climate change. We recognise that we have a responsibility to adhere to the guiding principles of the UK Sustainable Development Strategy – live within environmental limits, ensure a strong and healthy society, achieve a sustainable economy, promote good governance and use sound science responsibly. This means that we will respect the planet’s resources, take a precautionary and polluter pays approach to preserve the environment for future generation, incentivise resource efficiency, use sound scientific evidence to inform our policies where available and work with stakeholders to achieve these aims.
HOOP Cyber makes the following commitments both in respect of its own activities and, where appropriate, in its influence over the wider community:
To reduce our demand for natural resources and energy, to improve efficiency and to increase reliance on greener and renewable energy sources
To seek to minimise the waste produced from council activities, to recycle and to support the implementation of a Zero Waste Strategy
To continuously improve the sustainable management of our buildings, estates and transport reducing the emission of air pollutants and greenhouse gases
To be mindful of the impacts of climate change of the delivery of our services and increase the resilience of our services to impacts such as flooding and heatwaves
To prevent environmental harm or pollution incidents at all sites by ensuring our working practices comply with all relevant legislation
To ensure that all staff are aware of our environmental standards and shared responsibilities and encourage improvement in our supply chains and partnership networks
Through wider policies to protect and enhance the biodiversity of the UK.
Through wider policies support the conservation and enhancement of our built and natural environment
Through wider policies to ensure high quality of new development through good design.
To maintain continuous improvement by reviewing corporate policies and strategies to ensure integration of sustainable development principles and practices
To meet the commitments, HOOP Cyber will:
Use this policy as a framework for setting objectives and targets for environmental improvement
Operate effective management of environmental impacts
Communicate the requirements of this policy to all employees, suppliers and partners
Make this policy publicly available and keep the public informed of its environmental performance
This policy establishes an effective, accountable and transparent framework for ensuring compliance with the requirements of the GDPR.
2 SCOPE
This policy applies to all HOOP CYBER employees and all third parties responsible for the processing of personal data on behalf of HOOP CYBER services/entities. The content of this Policy also applies to our Charity’s Social Enterprise and trading arms, HOOP CYBER Paper Solutions and HOOP CYBER Training Solutions.
3 POLICY STATEMENT
HOOP CYBER is committed to conducting its business in accordance with all applicable data protection laws and regulations and in line with the highest standards of ethical conduct.
This policy sets forth the expected behaviours of HOOP CYBER employees and third parties in relation to the collection, use, retention, transfer, disclosure and destruction of any personal data belonging to a HOOP CYBER contact (i.e. the data subject).
Personal data is any information (including opinions and intentions) which relates to an identified or identifiable natural person. Personal data is subject to certain legal safeguards and other regulations, which impose restrictions on how organisations may process personal data. An organisation that handles personal data and makes decisions about its use is known as a Data Controller. HOOP CYBER, as a Data Controller, is responsible for ensuring compliance with the data protection requirements outlined in this policy. Non-compliance may expose HOOP CYBER to complaints, regulatory action, fines and/or reputational damage. HOOP CYBER, as a Data Processor is responsible for ensuring compliance with the requirements of the Data Controller and with the data protection requirements outlined in this policy. Non-compliance may expose HOOP CYBER to complaints, regulatory action, fines and/or reputational damage
HOOP CYBER’s leadership is fully committed to ensuring continued and effective implementation of this policy and expects all HOOP CYBER employees and third parties to share in this commitment. Any breach of this policy will be taken seriously and may result in disciplinary action or business sanction.
3.1. Governance
3.1.1. Data Protection Officer
To demonstrate our commitment to data protection, and to enhance the effectiveness of our compliance efforts, HOOP CYBER has appointed a Data Protection Officer. The Data Protection Officer operates with independence and is supported by suitability skilled individuals granted all necessary authority. The Data Protection Officer works with and reports to the Data Privacy Team at HOOP CYBER, made up of members of the Senior Management Team. The Data Protection Officer’s and the Data Privacy Team’s duties include:
Informing and advising HOOP CYBER and its employees who carry out processing pursuant to data protection regulations, national law or European Union based data protection provisions;
Ensuring the alignment of this policy with data protection regulations, national law or European Union based data protection provisions;
Providing guidance with regards to carrying out Data Protection Impact Assessments (DPIAs);
Acting as a point of contact for and cooperating with Data Protection Authorities (DPAs);
Determining the need for notifications to one or more DPAs because of HOOP CYBER’s current or intended personal data processing activities;
Making and keeping current notifications to one or more DPAs because of HOOP CYBER’s current or intended personal data processing activities;
The establishment and operation of a system providing prompt and appropriate responses to data subject requests;
Informing senior managers, officers, and directors of HOOP CYBER of any potential corporate, civil and criminal penalties which may be levied against HOOP CYBER and/or its employees for violation of applicable data protection laws.
Ensuring establishment of procedures and standard contractual provisions for obtaining compliance with this Policy by any third party who:
provides personal data to a HOOP CYBER service/entity
receives personal data from a HOOP CYBER service/entity
has access to personal data collected or processed by HOOP CYBER
3.1.2. Data Protection by Design
To ensure that all data protection requirements are identified and addressed when designing new systems or processes or services and/or when reviewing or expanding existing systems or processes or services, each of them must go through an approval process before continuing. Each HOOP CYBER service/entity must ensure that a Data Protection Impact Assessment (DPIA) is conducted, in cooperation with the Data Protection Officer, for all new and/or revised systems or processes for which it has responsibility. The subsequent findings of the DPIA must then be submitted to the Data Privacy Team for review and approval. Where applicable, the any third-party Information Technology (IT) contractors, as part of HOOP CYBER’s IT system and application design review process, will cooperate with the Data Protection Officer to assess the impact of any new technology uses on the security of personal data.
3.1.3. Compliance Monitoring
To confirm that an adequate level of compliance that is being achieved by all HOOP CYBER services/entities in relation to this policy, the Data Protection Officer will carry out an annual data protection compliance audit for all such services/entities. Each audit will, as a minimum, assess:
Compliance with policy in relation to the protection of personal data, including:
The assignment of responsibilities.
Raising awareness.
Training of employees.
The effectiveness of data protection related operational practices, including:
Data subject rights.
Personal data transfers.
Personal data incident management.
Personal data complaints handling.
The level of understanding of data protection policies and privacy notices.
The currency of data protection policies and privacy notices.
The accuracy of personal data being stored.
The conformity of data processor activities.
The adequacy of procedures for redressing poor compliance and personal data breaches. The Data Protection Officer, in cooperation with Data Privacy Team and Dept Heads from each HOOP CYBER service/entity, will devise a plan with a schedule for correcting any identified deficiencies within a defined and reasonable time frame. Any major deficiencies and good practice identified will be reported to, monitored and shared by the HOOP CYBER Data Privacy Team.
3.2. Data Protection Principles
HOOP CYBER has adopted the following principles to govern its collection, use, retention, transfer, disclosure and destruction of personal data:
Principle 1: Lawfulness, Fairness and Transparency. Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject. This means, HOOP CYBER must tell the data subject what processing will occur (transparency), the processing must match the description given to the data subject (fairness), and it must be for one of the purposes specified in the applicable data protection regulation (lawfulness).
Principle 2: Purpose Limitation. Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. This means HOOP CYBER must specify exactly what the personal data collected will be used for and limit the processing of that personal data to only what is necessary to meet the specified purpose.
Principle 3: Data Minimisation. Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. This means HOOP CYBER must not store any personal data beyond what is strictly required.
Principle 4: Accuracy. Personal data shall be accurate and, kept up to date. This means HOOP CYBER must have in place processes for identifying and addressing out-of-date, incorrect and redundant personal data.
Principle 5: Storage Limitation. Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. This means HOOP CYBER must, wherever possible, store personal data in a way that limits or prevents identification of the data subject.
Principle 6: Integrity & Confidentiality. Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing, and against accidental loss, destruction or damage. HOOP CYBER must use appropriate technical and organisational measures to ensure the integrity and confidentiality of personal data is maintained at all times.
Principle 7: Accountability. The Data Controller shall be responsible for, and be able to demonstrate compliance. This means HOOP CYBER must demonstrate that the six data protection principles (outlined above) are met for all personal data for which it is responsible.
3.3. Data collection
3.3.1. Data Sources
Personal data should be collected only from the data subject unless one of the following apply:
The nature of the business purpose necessitates collection of the personal data from other persons or bodies. E.g. Benefit Information, job references, DBS information.
The collection must be carried out under emergency circumstances in order to protect the vital interests of the data subject or to prevent serious loss or injury to another person. E.g. Jobseeker Safeguarding
If personal data is collected from someone other than the data subject, the data subject must be informed of the collection unless one of the following apply:
The data subject has received the required information by other means.
The information must remain confidential due to a professional secrecy obligation
A national law expressly provides for the collection, processing or transfer of the personal data.
Where it has been determined that notification to a data subject is required, notification should occur promptly, but in no case later than:
One calendar month from the first collection or recording of the personal data
At the time of first communication if used for communication with the data subject
At the time of disclosure if disclosed to another recipient.
3.3.2. Data subject consent
Each HOOP CYBER service/entity will obtain personal data only by lawful and fair means and, where appropriate with the knowledge and consent of the individual concerned. Where a need exists to request and receive the consent of an individual prior to the collection, use or disclosure of their personal data, HOOP CYBER is committed to seeking such consent. The Data Protection Officer, in cooperation with other relevant business representatives, shall establish a system for obtaining and documenting data subject consent for the collection, processing, and/or transfer of their personal data.
3.3.3. Data subject Notification
Each HOOP CYBER service/entity will, when required by applicable law or contract, or where it considers that it is reasonably appropriate to do so, provide data subjects with information as to the purpose of the processing of their personal data. When the data subject is asked to give consent to the processing of personal data and when any personal data is collected from the data subject, all appropriate disclosures will be made, in a manner that draws attention to them, unless one of the following apply:
The data subject already has the information;
A legal exemption applies to the requirements for disclosure and/or consent. The disclosures may be given orally, electronically or in writing. If given orally, the person making the disclosures should use a suitable script or form approved in advance by the Data Protection Officer. The associated receipt or form should be retained, along with a record of the facts, date, content, and method of disclosure.
3.3.4. External Privacy Notices
Each external website provided by HOOP CYBER will include an online ‘Privacy Notice’ and an online ‘Cookie Notice’ fulfilling the requirements of applicable law.
3.4. Data Use
3.4.1. Data processing
HOOP CYBER uses the personal data of its contacts for the following broad purposes:
The general running and business administration of HOOP CYBER services/entities.
To provide services to HOOP CYBER’s stakeholders.
The ongoing administration and management of customer services.
The use of a contact’s information should always be considered from their perspective and whether the use will be within their expectations or if they are likely to object. For example, it would clearly be within a contact’s expectations that their details will be used by HOOP CYBER to respond to a contact request for information about the products and services on offer. However, it will not be within their reasonable expectations that HOOP CYBER would then provide their details to third parties for marketing purposes.
Each HOOP CYBER service/entity will process personal data in accordance with all applicable laws and applicable contractual obligations. More specifically, HOOP CYBER will not process personal data unless at least one of the following requirements are met:
The data subject has given consent to the processing of their personal data for one or more specific purposes.
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Processing is necessary for compliance with a legal obligation to which the Data Controller is subject.
Processing is necessary in order to protect the vital interests of the data subject or of another natural person.
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.
Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller/Processor or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, in particular where the data subject is a child).
There are some circumstances in which personal data may be further processed for purposes that go beyond the original purpose for which the personal data was collected. When making a determination as to the compatibility of the new reason for processing, guidance and approval must be obtained from the Data Protection Officer before any such processing may commence.
In any circumstance where consent has not been gained for the specific processing in question, HOOP CYBER will address the following additional conditions to determine the fairness and transparency of any processing beyond the original purpose for which the personal data was collected: Any link between the purpose for which the personal data was collected and the reasons for intended further processing.
The context in which the personal data has been collected, in particular regarding the relationship between data subject and the Data Controller.
The nature of the personal data, in particular whether special ccategories of data are being processed, or whether personal data related to criminal convictions and offences are being processed.
The possible consequences of the intended further processing for the data subject.
The existence of appropriate safeguards pertaining to further processing, which may include encryption, anonymisation or pseudonymisation.
3.4.2. Special Categories of Data
HOOP CYBER will only process special categories of data (also known as sensitive data) where the data subject expressly consents to such processing or where one of the following conditions apply:
The processing relates to personal data which has already been made public by the data subject.
The processing is necessary for the establishment, exercise or defence of legal claims.
The processing is specifically authorised or required by law.
The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent.
Further conditions, including limitations, based upon national law related to the processing of genetic data, biometric data or data concerning health.
In any situation where, special categories of data are to be processed, prior approval must be obtained from the Data Protection Officer, and the basis for the processing clearly recorded with the personal data in question. Where special categories of data are being processed, HOOP CYBER will adopt additional protection measures.
3.4.3. Children’s Data
Children under the age of 14 are unable to consent to the processing of personal data for information society services (any service normally provided for payment, by electronic means and at the individual request of a recipient of services). Consent must be sought from the person who holds parental responsibility over the child. However, it should be noted that where processing is lawful under other grounds, consent need not be obtained from the child or the holder of parental responsibility.
3.4.4. Data Quality
Each HOOP CYBER service/entity will adopt all necessary measures to ensure that the personal data it collects, and processes is complete and accurate in the first instance, and is updated to reflect the current situation of the data subject. The measures adopted by HOOP CYBER to ensure data quality include:
Correcting personal data known to be incorrect, inaccurate, incomplete, ambiguous, misleading or outdated, even if the data subject does not request rectification.
Keeping personal data only for the period necessary to satisfy the permitted uses or applicable statutory retention period.
The removal of personal data if in violation of any of the data protection principles or if the personal data is no longer required.
Restriction, rather than deletion of personal data, insofar as:
a law prohibits erasure.
erasure would impair legitimate interests of the data subject.
the data subject disputes that their personal data is correct and it cannot be clearly ascertained whether their information is correct or incorrect.
3.4.5. Profiling & Automated Decision Making
HOOP CYBER will only engage in profiling and automated decision-making where it is necessary to enter into, or to perform, a contract with the data subject or where it is authorised by law. Where an HOOP CYBER service/entity utilises profiling and automated decision-making, this will be disclosed to the relevant data subjects. In such cases the data subject will be given the opportunity to:
Express their point of view.
Obtain an explanation for the automated decision.
Review the logic used by the automated system.
Supplement the automated system with additional data.
Have a human carry out a review of the automated decision.
Contest the automated decision.
Object to the automated decision-making being carried out. Each HOOP CYBER service/entity must also ensure that all profiling and automated decision-making relating to a data subject is based on accurate data.
3.4.6. Digital Marketing
As a rule, HOOP CYBER will not send promotional or direct marketing material to an HOOP CYBER contact through digital channels such as mobile phones, email and the Internet, without first obtaining their consent. Any HOOP CYBER service/entity wishing to carry out a digital marketing campaign without obtaining prior Consent from the data subject must first have it approved by the Data Protection Officer. Where personal data (e.g. case studies or photographs) processing is approved for digital marketing purposes, the data subject must be informed at the point of first contact that they have the right to object, at any stage, to having their data processed for such purposes. If the data subject puts forward an objection, digital marketing related processing of their personal data must cease immediately, and their details should be kept on a suppression list with a record of their opt-out decision, rather than being completely deleted. It should be noted that where digital marketing is carried out in a ‘business to business’ context, there is no legal requirement to obtain an indication of Consent to carry out digital marketing to individuals provided that they are given the opportunity to opt-out.
3.5. Data Retention
To ensure fair processing, personal data will not be retained by HOOP CYBER for longer than necessary in relation to the purposes for which it was originally collected, or for which it was further processed. The length of time for which HOOP CYBER services/entities need to retain personal data is set out in HOOP CYBER’s ‘Data Retention Policy’. This considers the legal and contractual requirements, both minimum and maximum, that influence the retention periods set forth in the schedule. All personal data should be deleted or destroyed as soon as possible where it has been confirmed that there is no longer a need to retain it.
3.6. Data Protection
Each HOOP CYBER service/entity will adopt physical, technical, and organisational measures to ensure the security of personal data. This includes the prevention of loss or damage, unauthorised alteration, access or processing, and other risks to which it may be exposed by virtue of human action or the physical or natural environment. A summary of the personal data related security measures is provided below:
Prevent unauthorised persons from gaining access to data processing systems in which personal data are processed.
Prevent persons entitled to use a data processing system from accessing personal data beyond their needs and authorisations.
Ensure that personal data in the course of electronic transmission during transport cannot be read, copied, modified or removed without authorisation.
Ensure that access logs are in place to establish whether, and by whom, the personal data was entered into, modified on or removed from a data processing system.
Ensure that in the case where processing is carried out by a Data Processor, the data can be processed only in accordance with the instructions of the Data Controller.
Ensure that personal data is protected against undesired destruction or loss.
Ensure that personal data collected for different purposes can and is processed separately.
Ensure that personal data is not kept longer than necessary
3.7. Data subject Requests
The Data Protection Officer will establish a system to enable and facilitate the exercise of data subject rights related to:
Information access.
Objection to processing.
Objection to automated decision-making and profiling.
Restriction of processing.
Data portability.
Data rectification.
Data erasure. If an individual makes a request relating to any of the rights listed above
HOOP CYBER will consider each such request in accordance with all applicable data protection laws and regulations. No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be unnecessary or excessive in nature. data subjects are entitled to obtain, based upon a request made in writing/email to: .
It should be noted that situations may arise where providing the information requested by a data subject would disclose personal data about another individual. In such cases, information must be redacted or withheld as may be necessary or appropriate to protect that person’s rights. Detailed guidance for dealing with requests from data subjects can be found in HOOP CYBER’s ‘Data Subject Access Rights Policy and Procedure’ document.
3.8. Law Enforcement Requests & Disclosures
In certain circumstances, it is permitted that personal data be shared without the knowledge or consent of a data subject. This is the case where the disclosure of the personal data is necessary for any of the following purposes:
The prevention or detection of crime.
The apprehension or prosecution of offenders.
The assessment or collection of a tax or duty.
By the order of a court or by any rule of law.
If an HOOP CYBER service/entity processes personal data for one of these purposes, then it may apply an exception to the processing rules outlined in this policy but only to the extent that not doing so would be likely to prejudice the case in question. If any HOOP CYBER service/entity receives a request from a court or any regulatory or law enforcement authority for information relating to an HOOP CYBER contact, you must immediately notify the Data Protection Officer who will provide comprehensive guidance and assistance.
3.9. Data Protection Training
All HOOP CYBER employees that have access to personal data will have their responsibilities under this policy outlined to them as part of their staff induction training. In addition, each HOOP CYBER service/entity will receive regular Data Protection training and procedural guidance.
3.10. Data Transfers
HOOP CYBER services/entities may transfer personal data to internal or third-party recipients located in another country where that country is recognised as having an adequate level of legal protection for the rights and freedoms of the relevant data subjects. Where transfers need to be made to countries lacking an adequate level of legal protection (i.e. third countries), they must be made in compliance with an approved transfer mechanism. HOOP CYBER services/entities may only transfer personal data where one of the transfer scenarios list below applies:
The data subject has given Consent to the proposed transfer.
The transfer is necessary for the performance of a contract with the data subject
The transfer is necessary for the implementation of pre-contractual measures taken in response to the data subject’s request.
The transfer is necessary for the conclusion or performance of a contract concluded with a third party in the interest of the data subject.
The transfer is legally required on important public interest grounds.
The transfer is necessary for the establishment, exercise or defence of legal claims.
The transfer is necessary in order to protect the vital interests of the data subject
3.11. Complaints handling
Data subjects with a complaint about the processing of their personal data, should put forward the matter in writing to the Data Protection Officer. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case. The Data Protection Officer will inform the data subject of the progress and the outcome of the complaint within a reasonable period. If the issue cannot be resolved through consultation between the data subject and the Data Protection Officer, then the data subject may, at their option, seek redress through mediation, binding arbitration, litigation, or via complaint to the Data Protection Authority within the applicable jurisdiction.
3.12. Breach Reporting
Any individual who suspects that a personal data breach has occurred due to the theft or exposure of personal data must immediately notify the Data Protection Officer providing a description of what occurred. Notification of the incident can be made via e-mail, by calling, or by using the independent ICO Data Concern line on: 0303 123 1113. The Data Protection Officer will investigate all reported incidents to confirm whether or not a personal data breach has occurred. If a personal data breach is confirmed, the Data Protection Officer will follow the relevant HOOP CYBER ‘Data Breach Notification Policy and Procedure’ based on the criticality and quantity of the personal data involved. For severe personal data breaches, HOOP CYBER’s Data Privacy Team will initiate and chair an emergency response team to coordinate and manage the personal data breach response.
4 ROLES AND RESPONSIBILITIES
4.1 Implementation
The senior management team and senior staff of each HOOP CYBER service/entity must ensure that all HOOP CYBER employees responsible for the processing of personal data are aware of and comply with the contents of this policy. In addition, each HOOP CYBERs service/entity will make sure all third parties engaged to process personal data on their behalf (i.e. their data processors) are aware of and comply with the contents of this policy. Assurance of such compliance must be obtained from all third parties, whether companies or individuals, prior to granting them access to personal data controlled by HOOP CYBER.
4.2 Support, Advice and Communication
For advice and support in relation to this policy, please contact Simon Johnson via
5 REVIEW
This policy will be reviewed by the Data Protection Officer/Data Privacy Team every three years, unless there are any changes to regulations or legislation that would enable a review earlier.
6 RECORDS MANAGEMENT
Staff must maintain all records relevant to administering this policy and procedure in electronic form in a recognised HOOP CYBER recordkeeping system.
All records relevant to administering this policy and procedure will be maintained for a period of 5 years.
7 TERMS AND DEFINITIONS
General Data Protection Regulation (GDPR): The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a regulation by which the European Parliament, the Council of the European Union and the European Commission intend to strengthen and unify data protection for all individuals within the European Union (EU). It also addresses the export of personal data outside the EU.
Data Controller: the entity that determines the purposes, conditions and means of the processing of personal data.
Data Processor: the entity that processes data on behalf of the Data Controller.
Data Protection Authority: national authorities tasked with the protection of data and privacy as well as monitoring and enforcement of the data protection regulations within the Union.
Data Protection Officer (DPO): an expert on data privacy who works independently to ensure that an entity is adhering to the policies and procedures set forth in the GDPR.
Data subject: a natural person whose personal data is processed by a controller or processor.
Personal data: any information related to a natural person or ‘data subject’, that can be used to directly or indirectly identify the person.
Privacy Impact Assessment: a tool used to identify and reduce the privacy risks of entities by analysing the personal data that are processed and the policies in place to protect the data.
Processing: any operation performed on personal data, whether or not by automated means, including collection, use, recording, etc.
Profiling: any automated processing of personal data intended to evaluate, analyse, or predict data subject behaviour.
Regulation: a binding legislative act that must be applied in its entirety across the Union.
Subject Access Right: also known as the Right to Access, it entitles the data subject to have access to and information about the personal data that a controller has concerning them.
While technology plays a crucial role, we firmly believe that successful cybersecurity requires a comprehensive approach. We offer our clients more than just data engineering expertise:
Security process optimization: We don’t simply implement technology; we assess and optimize existing security processes. This involves identifying and eliminating redundancies, streamlining workflows, and ensuring alignment with data-driven insights for improved efficiency.
Empowering through training: We invest in user education and awareness programs to create a human firewall. By equipping employees with the knowledge and skills to identify and report suspicious activity, we bolster the overall security posture.
Staying ahead of threats: We provide access to real-time threat intelligence feeds, keeping organizations informed about the latest threats, vulnerabilities, and attacker tactics. This enables proactive security measures and informed decision-making.
We recognize that cybersecurity solutions can be costly, and organizations are increasingly focused on maximizing the return on their security investments. HOOP Cyber prioritizes cost optimization alongside security effectiveness by:
Standardization and automation: We advocate for the standardization of security architectures and the automation of repetitive tasks. This streamlines operations, reduces manual effort, and ultimately translates to cost savings.
Cloud-based security solutions: We leverage the inherent scalability and cost benefits of cloud-based security solutions. This reduces upfront capital expenditures and allows organizations to pay only for the resources they use.
Open-source integration: Where applicable, we integrate open-source security tools alongside commercial solutions. This provides organizations with comparable functionality at a lower cost, allowing them to stretch their security budget further.
SIEM (Security Information and Event Management) deployment is a critical component in modern cybersecurity strategies, enabling organizations to detect, analyze, and respond to security threats in real time. The deployment process begins with thorough planning and preparation, which involves defining the specific security objectives and requirements, assessing the current IT infrastructure, and selecting the appropriate SIEM solution that aligns with the organization’s needs. This stage also includes configuring data sources such as network devices, servers, applications, and security tools to ensure they generate relevant logs and event data that the SIEM system can collect and analyze. Properly setting up these data inputs is crucial for the SIEM to provide comprehensive visibility into the organization’s security posture.
Once the SIEM solution is selected and data sources are configured, the actual deployment involves integrating the SIEM system into the existing IT environment. This includes installing the SIEM software, configuring network settings, and setting up user roles and permissions. After the installation, the SIEM system undergoes a tuning process to filter out false positives and refine alert thresholds to ensure the alerts generated are relevant and actionable. Continuous monitoring and regular updates are essential to maintain the effectiveness of the SIEM deployment. Additionally, staff training is vital to ensure that security personnel can effectively utilize the SIEM tools to investigate incidents and respond to threats. By successfully deploying a SIEM system, organizations can significantly enhance their ability to monitor, detect, and respond to security incidents, thereby improving their overall security posture.
