Data Ethics
1. Introduction
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This policy describes how data ethics is considered and included in the use of data and design and implementation of technologies used for processing of data at the OAYKAY Group. The policy applies in all aspects of processing of data whether the data enables identification of a natural person (“personal data”) or not.
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2. Principles for data ethics
When the OAYKAY Group processes data or designs, purchases or implements technologies, especially new technologies, for processing of data, the principles for data ethics described below must be assessed and included in the considerations during the design process and/or prior to the purchase or implementation of the processing activity or the technology used for the processing of data.
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Legality
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The processing of data shall, at all times, comply with applicable legislation. For example, the processing of personal data requires a specific legal basis according to the Information Technology Rules, 2011
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Ethical design
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Technologies for the processing of data, especially new technologies, shall be designed to respect principles of data ethics, including the principles laid down in this policy and the general processing principles as laid down under the Information Technology Rules, 2011. For example, technologies shall be designed to ensure correct and timely deletion of personal data in accordance with the OAYKAY Group’s retention periods.
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Expectations
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Data shall be processed in ways that are consistent with the intentions, expectations and under-standing of the disclosing party. For example, personal data may not be processed for new purposes which are incompatible with the purposes for which the personal data was originally collected.
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Security
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A sufficient level of security shall be implemented in and around technologies used for processing of data. The security measures shall include technical as well as organisational measures, and the sufficient level of security shall be assessed based on a risk assessment of the specific processing activity and the technology used for the processing of data.
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Respect for human rights
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Processing of data and the design of technologies used for processing of data shall ensure that human rights are respected. For example, processing of data or use of technologies for the processing of data may not be biased with a risk of discrimination, marginalisation or stigmatisation against individuals.
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Proportionality
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Data shall be used only for purposes which are proportional taking into account the rights of the individuals, including the right of privacy.
3. Use of data
The OAYKAY Group is developing, producing and selling hand tool and accessories. The group is primarily focused on business to business relationships which entails that the group is primarily in possession of business to business information, including contact information regarding contact persons with business partners.
4. Use of new technology and profiling
Where the KOAYKAY Group wishes to implement changes to the use of new technologies or profiling the principles set out in section 2 of this policy must be respected.
5. Training of employees
The OAYKAY Group ensures that employees who, as a part of their job with the OAYKAY Group, use data or are engaged in designing, purchasing or implementing technologies for the use of data, receive training in the principles for data ethics described in section 2 above, and in complying with this policy, on a regular basis.
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If the OAYKAY Group finds that certain employees need additional training or more frequent training than described above in section 5.1, the OAYKAY Group ensures that such employees receive the training deemed necessary to ensure compliance with this policy.
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The OAYKAY Group ensures that this policy is available to employees with the purpose of ensuring the employees’ access to the applicable principles for data ethics for the OAYKAY Group.
6. Responsibility
OAYKAY Group’s Director HR is responsible for and oversees The OAYKAY Group’s compliance, including compliance with data ethics and this policy.
7. Questions
Any questions regarding this policy or data ethics may be addressed to the Group Compliance Officer.