Privacy Policy
Parkland Industrial Company Limited
Policy became operational on: August 13, 2024
Introduction
Parkland Industrial Company Co. Limited obtains, uses and retains personal data of individuals as part of our day-to-day activities and for various specific lawful purposes as set out in privacy notices, contracts, and / or web-site information. These individuals can include staff, customers, partners and other individuals 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 Jamaica Data Protection Act.
Why this policy exists
This privacy policy ensures Parkland Industrial Company Limited:
● Complies with Jamaica Data Protection Act
● Follows best practices
● Protects the rights of staff, customers and partners
● Is transparent about how it stores and processes individuals’ data
● Protects itself from the risks of a data breach
The Data Protection Act
The Jamaica Data Protection Act 2020 describes how organizations — including Parkland Industrial Company Limited — 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 or standards as they are called within the Act. 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 using technical and organizational measures
8. Not be transferred outside the country, unless that country or territory also ensures an adequate level of protection
Policy scope
This policy applies to:
● The head office of Parkland Industrial located at 237 Marcus Garvey Drive, Kingston 11
● The sales depot of Parkland Industrial located at Warehouse #8 Twickenham Park Mini Warehouse Complex
● All staff and volunteers of Parkland Industrial
● All contractors, suppliers and other people working on behalf of Parkland Industrial
It applies to all data that the company holds relating to identifiable individuals. This can include:
● Contact Information
● Demographic information
● Government-issued identification
● Employment information
● Education information
● Filiation information
● Financial information
● Health information
● Vendor and partner information
● IT and network data
● Biometric data
● Customer information
● Insurance information
● Criminal records
● CCTV footage
People, risks and responsibilities
Data protection risks
This policy helps to protect Parkland Industrial Company Limited from data security and privacy risks, including:
● Breaches of confidentiality. For instance, information disclosed inappropriately.
● Misuse of personal data, where employees lack knowledge of how to handle personal data appropriately, in line with the requirements of the Jamaica Data Protection Act.
● Reputational damage. For instance, the company could suffer loss of trust by customers, financial loss and legal penalties if hackers successfully gained access to personal and sensitive data.
Responsibilities
Everyone who works for or with Parkland Industrial Company Limited has the responsibility of ensuring that 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 applicable legislation. However, these people have key areas of responsibility:
● The Board of Directors is ultimately responsible for ensuring that
Parkland Industrial Company Limited 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 Providing oversight to ensure that personnel in charge of managing data subject access requests fulfill them accordingly and without undue delay.
o Providing guidance on any contracts or agreements with third parties that may process personal and sensitive data on behalf of the company.
● The IT Service Provider 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 are functioning properly.
o Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
● The Data Governance committee is responsible for:
o Establishing and enforcing policies related to data management
o Oversight of data quality, privacy and compliance, ensuring that data related processes align with organizational goals and regulatory requirements
o Establishing standard business rules for data collection, sharing, and reporting to streamline operations across the company
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 all initiatives relating to processing of personal data abide by data protection standards.
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 must request it from their line managers.
● Parkland Industrial Company Limited will provide training to all employees to help them understand their responsibilities when handling data.
● When responding to a data subject access request, employees must ensure they verify the identity of the requestor at all times, including confirming responses to security questions.
● Third party service providers who process data on behalf of Parkland Industrial Company Limited must be assessed to ensure they have robust data protection and security measures implemented to adequately safeguard data. Data sharing agreements which include provisions related to data handling, confidentiality, data security, compliance and the right to audit the third-party’s practices must be in place as well.
● Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
● Strong passwords must be used which 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 securely 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 Service Provider
When data is stored on paper, it should be kept in a secure and designated area where unauthorized people cannot access 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 can access them, like on a printer.
● A clean desk policy is to be observed at all times i.e., employees are to maintain a clean and organized workspace by removing all unnecessary items from their desk at the end of each workday. Documents containing personal and sensitive data should never be left unattended at an employee’s desk.
● 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), 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 approved cloud computing services.
● Servers containing personal data should be sited in a secure, designated 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 smartphones.
● All servers and computers containing data should be protected by approved security software and a firewall
Data use
Employees play a crucial role in safeguarding the personal data which Parkland Industrial Company Limited collects and processes. Consideration must be taken at all times when handling this data.
● When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
● Personal data should not be shared informally.
● If there is a need to send personal data by email, ensure the file is password protected. or encrypted.
● Data must be encrypted before being transferred electronically. IT Service Provider can explain how to send data to authorized external contacts.
● Employees should not save copies of personal data to their own computers. Always access personal data using the company issued devices.
Data accuracy
The law requires Parkland Industrial Company Limited to take reasonable steps to ensure data is kept accurate and up to date. 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. Employees should not create any unnecessary additional data sets.
● Employees should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call or visit the office.
● Parkland Industrial will make it easy for data subjects to update the information we hold about them.
● Data should be updated as soon as inaccuracies are discovered. For instance, if the ID for a customer on file has expired, they should be contacted to update the record.
Data subject access requests
All individuals who are the subject of personal data held by Parkland Industrial Company Limited are entitled to:
● Ask what information the company holds about them and why.
● Ask to obtain a copy of the personal data we have about them.
● Be informed on how to keep it accurate and up to date.
● Be informed how the company is meeting its data protection obligations.
● Ask us to stop directly marketing to them
● Ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or processed or to rectify inaccurate data or to complete incomplete data.
● Ask us to cease or restrict processing in certain circumstances
● Ask that a human reviews decisions which have been made about them by purely automated means.
If an individual contacts the company requesting this information, this is called a data subject access request, which the company must comply with within 30 days. Data subject access requests from individuals should be made by email, phone call, mail, or in-person. The data controller will aim to provide the relevant data within a reasonable timeframe. Parkland Industrial Company Limited will always verify the identity of anyone making a data 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, Parkland Industrial Company Limited will disclose the requested data. However, Parkland Industrial Company Limited will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Providing information
Parkland Industrial Company Limited aims to ensure that individuals are aware that their data is being processed, and that they understand:
● How the data is being used
● Who their data is shared with
● Purposes for which their data is processed
● How to exercise their rights
To this end, the company has a privacy notice, setting out how data relating to individuals is used by the company. The privacy notice or statement referencing this privacy policy must be attached with all documentation given to an individual at the time of data collection. The privacy notice must also be available on request.
Usage Data
We may collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that
you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
● Session Cookies. We use Session Cookies to operate our Service.
● Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
● Security Cookies. We use Security Cookies for security purposes.
Changes to this Data Protection Policy
We will keep this Data Protection Policy under periodic review and may update it accordingly. We will let you know via email and/or a prominent notice on our service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
Contact Us
If you have any questions about this privacy policy, please contact us:
By email:
By phone: (876) 618-6187
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