Mcardit Data Protection Policy
In order to fulfill its role as a conduit between the platform registered user, merchant and payment service provider, Mcardit needs to gather and use certain information about individuals and businesses. 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.
WHY THIS POLICY EXISTS
This data protection policy ensures Mcardit:
- Complies with data protection law and follow good practice
- Protects the rights of staff, customers and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of a data breach
DATA PROTECTION LAW
Data protection laws describe how organizations — including Mcardit— 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 these laws, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
Personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
In particular, this policy is designed to assure adherence to the following legal and regulatory guidelines:
- California Consumer Privacy Act (CCPA)
- Gramm-Leach-Bliley Act (GLBA)
- General Data Protection Regulation (GDPR)
Mcardit does not operate or fall under GDPR jurisdiction, however, our organization still strives to abide by best practices as outlined in the GDPR.
This policy applies to:
- All “physical” Mcardit locations
- All staff and volunteers of Mcardit
- All contractors, suppliers and other people working on behalf of Mcardit
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside data protection laws. This can include:
- Names of individuals or businesses
- Postal addresses
- Email addresses
- Telephone numbers
- Bank account information
- Government issued identifying numbers
DATA PROTECTION RISKS
This policy helps to protect Mcardit 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.
Everyone who works for or with Mcardit 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 executive management team is ultimately responsible for ensuring that Mcardit meets its legal obligations.
- Chief technical officers are responsible for:
- Keeping the management team 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 Mcardit 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.
- Technical and security infrastructure employees are 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.
- Operations and marketing teams are 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.
- Mcardit 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 AND TRANSMISSION
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT department 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 or transmitted 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.
- Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing service.
- 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 should always be protected with strong encryption while at rest and in transit.
Personal data is of no value to Mcardit 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, employees should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
- Data must be encrypted before being transferred electronically. All email and networks default to secure and encrypted settings.
- Employees should not save copies of personal data to their own computers as per the Mcardit Device Management + Identity and Access policies.
- Always access and update the central copy of any data.
The law requires Mcardit 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 Mcardit 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 customer’s details when they call.
- Mcardit will make it easy for data subjects to update the information Mcardit holds about them. For instance, via the company website.
- Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
SUBJECT ACCESS REQUESTS
We comply with relevant laws and regulations, including the California Consumer Privacy Act (CCPA), the General Data Protection Regulation (GDPR), and the Gramm-Leach-Bliley Act (GLBA), which provide certain rights to individuals regarding their personal information. These rights may include the right to request access to or deletion of your personal information, and the right to opt out of the sale of your personal information.
Although you retain the right to request an “opt-out” of the sale of personal data, Mcardit will never sell your personal information regardless of your request status
These requests are known as “Subject Access Requests” and may include consumer requests 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**.
Subject access requests from individuals should be made by email, addressed to the data controller at privacy@Mcardit.com. The data controller can supply a standard request form, although individuals do not have to use this.
We will respond to your request within a reasonable time frame and may require additional information to verify your identity.
DISCLOSING DATA FOR OTHER REASONS
In certain circumstances, the data privacy laws allow personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Mcardit 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.
Mcardit 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
26391 Crown Valley Parkway, Suite 240
Mission Viejo, CA 92691
v1.1 updated September 1, 2023