Internal Data Protection Policy

**Internal Data Protection Policy**

**1. Purpose**

The purpose of this policy is to outline the measures and guidelines for protecting sensitive data within Together Software Ltd. This policy aims to safeguard confidential information, uphold privacy rights, and ensure compliance with relevant laws and regulations.

**2. Scope**

This policy applies to all employees, contractors, and third parties who have access to Together Software Ltd's data assets, regardless of the format or location of the data.

**3. Data Classification**

Data shall be classified into categories based on sensitivity and potential impact, such as:

- Public: Information intended for public dissemination.
- Internal: Information for internal use only, not intended for external distribution.
- Confidential: Highly sensitive information requiring strict access controls.

**4. Data Handling Procedures**

- Access Control: Access to confidential data shall be restricted to authorized personnel only. Employees shall use unique credentials for accessing data systems and adhere to the principle of least privilege.
- Data Storage: Confidential data must be stored securely using encryption and access controls. Physical storage devices shall be kept in locked cabinets or rooms.
- Data Transmission: Data transmitted electronically shall be encrypted using secure protocols to prevent interception.
- Data Disposal: When data is no longer needed, it shall be securely deleted or disposed of in accordance with Together Software Ltd's data retention policy.

**5. Employee Responsibilities**

- Confidentiality: Employees must maintain the confidentiality of sensitive information and refrain from disclosing it to unauthorized parties.
- Training: All employees shall receive training on data protection policies and procedures to ensure awareness and compliance.
- Reporting: Any suspected breaches or violations of this policy must be reported to the designated data protection officer or IT security team immediately.

**6. Monitoring and Compliance**

- Regular Audits: Together Software Ltd shall conduct periodic audits to assess compliance with this policy and identify any vulnerabilities or weaknesses in data protection measures.
- Enforcement: Violations of this policy may result in disciplinary action, up to and including termination of employment or legal prosecution.

**7. Data Breach Response**

In the event of a data breach or unauthorized access, Together Software Ltd shall follow established incident response procedures to contain the breach, mitigate damages, and notify affected individuals and regulatory authorities as required by law.

**8. Policy Review and Updates**

This policy shall be reviewed and updated regularly to reflect changes in technology, regulations, and business practices. Employees shall be notified of any revisions to ensure ongoing compliance.

**9. Compliance with Laws and Regulations**

Together Software Ltd is committed to complying with all relevant data protection laws and regulations, including but not limited to the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and any other applicable laws in the jurisdictions where we operate.

**10. Approval**

This data protection policy has been approved by Management and is effective as of 1st January 2024.