The Reserve Bank of India has made it mandatory that the aggregate exposure by an investor across all Peer to Peer Lending Platforms should be less than or equal to Rs. 10,00,000 and
the total exposure of a lender to a single borrower should be less than or equal to Rs. 50,000.

Data Security / Protection Policy


Introduction

MicroGraam Marketplace Pvt Ltd needs to gather and use certain information about individuals.

These can include customers, supplier’s business contacts, employees and other people the organization has a relationship with or may need to contact.

Why this policy exists?

This data protection policy ensures MicroGraam:

  • 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 individual’s data
  • Protects itself from the risks of data breach

Data protection law

The Data protection Act 1998 describes how organisations – including MicroGraam must collect, handle and store personal information.

These rules apply regardless of whether data is store electronically, on paper or on other materials.

To comply with law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data protection Act is underpinned by eight important principles. These say the personal data must:

  1. Be processed fairly and lawfully
  2. Be obtained only for specific, lawful purposes
  3. Be adequate, relevant and not excessive
  4. Be accurate and kept up to date
  5. Not be held for any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. Not be transferred outside the country unless that country or territory also ensures and adequate level of protection

People, risks and responsibility

Policy Scope

This policy applies to:

  • The head office of MicroGraam Marketplace
  • All branched of MicroGraam Marketplace
  • All staff and volunteers of MicroGraam Marketplace
  • All contractors, suppliers and other people working on behalf of MicroGraam Marketplace
  • It applies to all the data that the company holds relating to identifiable individuals, even if that information technically falls outside Data Protection Act 1998. This can include:

  • Names if Individuals
  • Postal addresses
  • Email Addresses
  • Telephone numbers
  • Any other information relating to individuals

Data Protection risks

This policy helps to protect MicroGraam Marketplace from some very real data security risks including:

  • Breaches of Confidentiality – For instance, information 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 gain access to sensitive data.

Responsibilities

Everyone who works for or with MicroGraam Marketplace 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.

The board of Directors is ultimately responsible for ensuring that MicroGraam Marketplace meets its legal obligations.

The data protection officer is responsible for:

  • Keeping the board updated about data protection responsibilities, risks and issues
  • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
  • Arranging data protection training and advice for the people covered by this policy.
  • Handling data protection questions from staff and anyone else covered by this policy.
  • Dealing with request from individuals to see the data MicroGraam Marketplace holds about them.
  • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

The IT manager is responsible for:

  • Ensuring all systems, services and equipment’s 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.

The Marketing manager is responsible for:

  • Approving any data protection statements attached to communication 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.
  • MicroGraam Marketplace will provide training to all employees to help them understand their responsibilities when handling data.
  • Employees should keep all data source, by taking sensible precautions and follow the guideline below.
  • Strong password 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 out of date. If no longer required, it should be deleted and disposed of.
  • Employees should request help from their line manager or data protection office if they are unsure about any aspect of data protection.

Data Classification

ClassificationDescriptionExample
Restricted DataData should be classified as Restricted when the unauthorized disclosure, alteration or destruction of that data could cause a significant level of risk to the University or its affiliates. The highest level of security controls should be applied to Restricted data.Data protected by state or central privacy regulations and data protected by confidentiality agreements. Undisclosed financial information.
Private DataData should be classified as Private when the unauthorized disclosure, alteration or destruction of that data could result in a moderate level of risk to the University or its affiliates. By default, all Institutional Data that is not explicitly classified as Restricted or Public data should be treated as Private data. A reasonable level of security controls should be applied to Private data.
Public DataData should be classified as Public when the unauthorized disclosure, alteration or destruction of that data would results in little or no risk to the University and its affiliates. Examples of Public data include press releases, course information and research publications. While little or no controls are required to protect the confidentiality of Public data, some level of control is required to prevent unauthorized modification or destruction of Public data.

Data Storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

When data is stored on paper, it should be kept in a secure place where unauthorized people cannot 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 could see them.
  • Data printouts should be shredded and disposed of securely when no longer required.

When data is store electronically, it must be protected from unauthorized access, accidental deletion and malicious hacking attempts.

  • Data should be protected by strong passwords and changed regularly and never share between employees.
  • If data is stored on removable media (CD, DVD or external hard drive), these should be kept locked securely when not being used.
  • Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing services.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Data should be backed up frequently. Those backups should be tested regularly, in line with company’s standard backup procedure.
  • Data should never be store in directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing should be protected by approved security software and firewall.

Data Use

Personal data of no value to MicroGraam Marketplace 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 share 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.
  • Employees should not save copies of personal data to their own computer. Always access and update the central copy of any data.

Data Transfer

Information should not be transferred to third party unless such a transfer is authorized by Data Security team.

All authorized data transfer should be carried out in most secured form available.

Data Accuracy

The law requires MicroGraam Marketplace 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 MicroGraam Marketplace 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 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 update,
  • It is the marketing managers responsibility to ensure marketing databases are checked against industry suppression files every six months.

Disclosing Data

In certain circumstances, the data protection act allows personal data to be disclosed to law enforcement agencies without consent of the data subject.

Under these circumstances MicroGraam Marketplace will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from company’s legal advisers where necessary.

Providing information

MicroGraam Marketplace aims to ensure that individuals are aware that their data is being processed, and that they understand:

  • How the data is being used
  • How to exercise their rights

To these end, the company has a privacy statement, setting out how data relating to individuals is used by the company

Training and awareness

All employees, upon obtaining employment with Microgram, will receive general information on the Institution’s and individual obligations thereunder as a component of the induction documentation and process.

Data breach management

All incidents of data breaches should be reported to Data Security team immediately.

The general procedure in the case of a data security breach will follow ICO guidelines and focus on the proper completion of four stages of breach management:

Containment and recovery

Assessment of on-going risk

Notification of breach

Evaluation and response