1. Purpose and scope
Galaxy Backbone Limited 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 behaviors of The Galaxy Backbone Limited Employees and Third Parties in relation to the collection, use, retention, transfer, disclosure and destruction of any Personally Identifiable Information. Galaxy Backbone Limited is responsible for ensuring compliance with the Data Protection requirements outlined in this policy. Non-compliance may expose the company to complaints, regulatory action, fines and/or reputational damage.
This policy applies to all Galaxy Backbone employees, managers and Third Parties who handle, process, control, access document, records, or information technology (IT) systems that contain privacy or personal identifiable information.
2. Legal Framework
· Nigeria Data Protection Regulation 2019
3. Policy Requirements
3.1.1. Data Stewards
The following are the Data stewards who will administer this policy in their respective areas of Galaxy Backbone operations. They will resolve the responsibility for the data, if any data elements overlap more than one area.
- Management Team
- Data Protection Officer
- Chief Information Security Officer (CISO)
- Human Resource
- Legal Services
3.1.2. Data Protection by Design
To ensure that all Data Protection requirements are identified and addressed when designing new systems or processes and/or when reviewing or expanding existing systems or processes, each of them must go through an approval process before continuing. Each Galaxy Backbone Service/Entity must ensure that a Data Protection Impact Assessment (DPIA) is conducted, in cooperation with the Data Stewards, 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 Management for review and approval.
3.1.3. Compliance Monitoring
To confirm that an adequate level of compliance is being achieved by Galaxy Backbone Limited in relation to this policy, the company will carry out Data Protection compliance audit from time to time.
3.2. Data Protection Principles
Galaxy Backbone Limited 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, Galaxy Backbone Limited 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 that Galaxy Backbone Limited will 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. Galaxy Backbone shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Principle 3: Data Minimization
Personal Data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. This means that Galaxy Backbone Limited will 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 Galaxy Backbone Limited will 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 that Galaxy backbone Limited will, 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 unauthorized or unlawful processing, and against accidental loss, destruction or damage. Galaxy Backbone Limited will ensure the use of appropriate technical and organizational measures to ensure the integrity and confidentiality of Personal Data is maintained at all times.
Principle 7: Accountability
Galaxy Backbone Limited shall be responsible for, and be in a position to demonstrate compliance. Galaxy Backbone Limited will take steps to ensure 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 shall be collected only from the Data Subject if one of the following conditions apply:
- The nature of the business purpose necessitates collection of the Personal Data from other persons or bodies.
- 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.
3.3.2. Data Subject Consent
No data shall be obtained except the specific purpose of collection is made known to the Data Subject. Galaxy Backbone Limited 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, Galaxy Backbone Limited is committed to seeking such consent. Data Stewards 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
Galaxy Backbone Limited will, when required by applicable law, 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 the Data Subject already has the information or a legal exemption applies to the requirements for disclosure and/or consent.
3.3.4. External Privacy Notices
External website provided by Galaxy Backbone Limited 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
Galaxy Backbone Limited uses the Personal Data of its contacts for the following broad purposes:
- The general running and business administration of Galaxy Backbone services.
- To provide services to Galaxy Backbone stakeholders and interested parties.
- The ongoing management and provision of customers’ services.
- To contact the Data Subject in furtherance of previous deliberations at our events or meetings.
- For compliance with legal and statutory requirements including but not limited to financial and official audit.
Galaxy Backbone Limited will process Personal Data in accordance with all applicable laws and applicable contractual obligations. More specifically, Galaxy Backbone Limited 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 on Galaxy backbone Limited.
3.4.2. Data Quality
Galaxy Backbone Limited 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 Galaxy Backbone Limited 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, if the law prohibits erasure.
3.5. Data Retention
To ensure fair processing, Personal Data will not be retained by Galaxy Backbone 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 Galaxy Backbone Limited need to retain Personal Data is set out in the Procedure for Document and Record Control. 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
Galaxy Backbone Limited will adopt physical, environmental, logical/technical, and administrative measures to ensure the security of Personal Data. This includes the prevention of loss or damage, unauthorized 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 unauthorized 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 authorizations.
- Ensure that Personal Data in the course of electronic transmission during transport cannot be read, copied, modified or removed without authorization.
- 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 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. 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 Galaxy Backbone Limited 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 Galaxy Backbone Limited receives a request from a court or any regulatory or law enforcement authority for information relating to the company’s contact, it must be notified to the Legal services department who will provide comprehensive guidance and assistance.
3.8. Data Protection Training
All Galaxy Backbone Limited 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, Galaxy Backbone Limited will provide regular Data Protection training and procedural guidance for staff responsible to ensure compliance with Data Protection policy.
- 3.9. Third Party Data Processing Contract
Data processing by a third party shall be governed by a written contract between the third party and the Galaxy Backbone Limited. Accordingly, any person engaging a third party to process the data obtained from Data Subjects shall ensure adherence to this policy.3.10. Data Transfers
Galaxy Backbone Limited may transfer Personal Data to internal or Third Party recipients located in another country where that country is recognized 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. Galaxy Backbone Limited may only transfer Personal Data where one of the scenarios outlined 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 defense of legal claims.
- The transfer is necessary in order to protect the vital interests of the Data Subject.
3.10.1. Transfers to Third Parties
Galaxy Backbone Limited will only transfer Personal Data to, or allow access by, Third Parties when it is assured that the information will be processed legitimately and protected appropriately by the recipient.
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 Managing Director, Galaxy Backbone Limited. 61, Adetokunbo Ademola Crescent, Wuse 2, Abuja. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case.
3.12. Breach Reporting
Any individual who suspects that a breach has occurred due to the theft or exposure of personal data must immediately notify our Service Desk to provide description of what occurred. Notification of the incident can be reported to firstname.lastname@example.org,ng.
3.13. Contact Us
For any questions, comments or clarifications about this policy, kindly contact our Data Protection Officer (DPO):
By Email: email@example.com
By Phone: +234 94 621 500 ext 80035