1: Introduction

1.1 Policy Overview
Redcone Recruitment Limited is committed to safeguarding the personal and sensitive data it holds, processes, and manages as part of its business operations. As a company involved in traffic management and the recruitment/supply of labour, Redcone Recruitment Limited handles a substantial amount of personal data, including employees, contractors, clients, and suppliers. In line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, this Data Breach Response Plan provides a clear framework for identifying, reporting, and responding to data breaches to mitigate potential harm to individuals and the organisation.

1.2 Purpose of the Plan
The purpose of this plan is to:

• Establish procedures for responding to a data breach, minimising damage and protecting individuals’ personal data.
• Ensure that data breaches are handled swiftly, thoroughly, and in compliance with UK GDPR and the Data Protection Act 2018.
• Provide guidance on the identification, reporting, containment, and communication of data breaches.
• Protect Redcone Recruitment Limited from the legal, financial, and reputational consequences of data breaches.

1.3 Legal Framework
This Data Breach Response Plan is in compliance with:

• UK GDPR: Sets out requirements for handling personal data breaches, including notification to the Information Commissioner’s Office (ICO) and affected individuals, where necessary.
• Data Protection Act 2018: Provides the legal framework for data protection in the UK.
• Privacy and Electronic Communications Regulations (PECR): Relates to the privacy of electronic communications.

Failure to comply with data protection legislation can result in significant fines, penalties, and reputational damage to Redcone Recruitment Limited.

2: Scope

2.1 Applicability
This plan applies to all employees, contractors, temporary staff, and third parties who have access to personal data held by Redcone Recruitment Limited. It covers all personal data, whether held electronically or in hard copy, as well as sensitive data as defined under UK GDPR, including but not limited to:

• Personal details (names, addresses, phone numbers)
• Financial information (bank details, payment records)
• Employment records (contractor details, salary, performance data)
• Sensitive data (medical information, criminal records)

2.2 What is a Data Breach?
A data breach refers to a security incident where personal data is lost, stolen, accessed, disclosed, altered, or destroyed without authorisation. Breaches can occur due to:

• Accidental Causes: Sending personal data to the wrong recipient, loss of a laptop or mobile device containing personal data, accidental deletion of records.
• Malicious Causes: Hacking, ransomware attacks, data theft by employees or third parties, unauthorised access to systems.
• Other Causes: Unauthorised disclosure of data, improper disposal of records containing personal data.

3: Roles and Responsibilities

3.1 Data Protection Officer (DPO)
The Data Protection Officer (DPO) is responsible for overseeing data protection compliance within Redcone Recruitment Limited and ensuring that all aspects of data breach management are handled correctly. Specific responsibilities include:

• Monitoring compliance with data protection laws.
• Leading data breach investigations and coordinating with relevant teams.
• Notifying the ICO and individuals affected, where applicable.
• Ensuring employees are aware of data protection policies and breach procedures.

3.2 Senior Management
Senior management is responsible for supporting data breach management efforts, allocating resources as needed, and ensuring that the organisation complies with legal requirements. They will:

• Assist the DPO in managing high-risk breaches.
• Make decisions regarding the escalation of breaches and any required disciplinary actions.

3.3 All Employees
All employees, contractors, and third parties are responsible for:

• Protecting personal data they handle in accordance with the Data Protection Policy.
• Immediately reporting any suspected or actual data breaches to the DPO.
• Following the instructions of the DPO or senior management during a breach response.

4: Data Breach Response Procedure

4.1 Step 1: Identification and Reporting of a Data Breach
When a potential data breach is identified, employees or third parties must report it immediately to the DPO by email, phone, or other company-established communication channels. Key details that should be provided when reporting a breach include:

• The nature of the breach (e.g., unauthorised access, loss of data, theft).
• The type and volume of data involved (e.g., personal details, financial records).
• The date and time the breach was identified.
• The person or system responsible for the breach, if known.

It is important to report the breach as soon as it is detected, even if all details are not yet clear. Any delay in reporting can worsen the potential impact.

4.2 Step 2: Containment and Mitigation
Once a data breach has been reported, the DPO, along with relevant IT or operational teams, will immediately take steps to contain and mitigate the breach. These actions may include:

• Isolating the affected systems to prevent further unauthorised access.
• Disabling compromised accounts or resetting user credentials.
• Retrieving lost or stolen data or equipment (e.g., recovering a lost laptop or disabling a misplaced device remotely).
• Suspending data processing or transfers if they are contributing to the breach.
• Assessing backups to ensure that data can be recovered if necessary.

If the breach involves external actors (e.g., cybercriminals), the company’s cybersecurity team or a third-party IT security consultant may be engaged to assist in containing the breach.

4.3 Step 3: Breach Assessment
The DPO will conduct a thorough investigation to assess the breach’s scope and impact. This assessment will include:

• Identifying what personal data has been compromised and whether sensitive data is involved.
• Determining the number of individuals affected.
• Assessing the potential consequences for individuals, including identity theft, financial loss, reputational damage, or harm to physical or mental well-being.
• Identifying whether the breach is likely to result in a high risk to the rights and freedoms of individuals.

This assessment is crucial for determining whether the breach must be reported to the ICO and the affected individuals.

4.4 Step 4: Notification

• Notification to the ICO: If the breach is likely to result in a risk to the rights and freedoms of individuals, Redcone Recruitment Limited must notify the ICO within 72 hours of becoming aware of the breach. The notification must include:
  • A description of the breach, including how and when it occurred.
  • The type and volume of personal data affected.
  • The number of individuals impacted.
  • The potential consequences of the breach.
  • The actions taken or proposed to mitigate the breach.
  • Contact details of the DPO or a designated contact person.
• Notification to Affected Individuals: If the breach is likely to result in a high risk to individuals (e.g., financial loss or identity theft), those affected must also be informed without undue delay. The notification should:
  • Explain the nature of the breach and the potential impact on them.
  • Provide guidance on steps they can take to protect themselves (e.g., changing passwords, monitoring financial statements).
  • Offer contact details for further information and support.

4.5 Step 5: Post-Breach Review and Remediation
After the immediate response to a breach has been completed, the DPO and senior management will conduct a post-breach review to:

• Analyse the root cause of the breach and how it occurred.
• Evaluate the effectiveness of the breach response and identify any gaps in the process.
• Implement corrective actions to prevent a recurrence, which may include:
  • Updating security measures and IT infrastructure.
  • Providing additional training to employees.
  • Reviewing and revising internal policies and procedures.

A full incident report will be compiled, documenting the breach, the response, and any lessons learned. This report will be made available to relevant internal stakeholders and, if necessary, external regulators.

5: Record-Keeping and Documentation

Redcone Recruitment Limited will maintain detailed records of all data breaches, regardless of whether they are reportable to the ICO. These records will include:

• The nature and description of the breach.
• The personal data affected.
• The risk assessment and justification for whether or not it was reported to the ICO.
• Actions taken in response to the breach.
• Notifications made to the ICO and individuals (if applicable).
• Any remedial steps taken to prevent future breaches.

These records will be retained in compliance with the company’s Data Retention Policy and the requirements of the UK GDPR.

6: Training and Awareness

6.1 Employee Training
Redcone Recruitment Limited will provide regular training on data protection and breach response procedures to all employees, ensuring that:

• Employees understand the importance of data security.
• They can identify potential data breaches.
• They know the correct procedures for reporting breaches.

Training will be mandatory for new employees as part of the onboarding process and will be refreshed regularly to account for changes in data protection regulations or company practices.

6.2 Management Training
Senior managers and department heads will receive additional training on managing and responding to data breaches. This training will cover:

• Their responsibilities in the event of a breach.
• How to support affected teams and individuals.
• How to collaborate with the DPO during breach investigations.

7: Monitoring and Review

7.1 Monitoring
The DPO and IT security teams will continuously monitor Redcone Recruitment Limited’s data systems for vulnerabilities and potential breaches. Regular audits will be conducted to ensure that data protection measures are effective and compliant with regulatory requirements.

7.2 Policy Review
This Data Breach Response Plan will be reviewed annually or whenever significant changes in legislation or company practices occur. Feedback from employees and lessons learned from any data breach incidents will be incorporated into future versions of the policy. Any updates will be communicated to all employees and stakeholders.

8: Conclusion

Redcone Recruitment Limited takes data protection seriously and is committed to safeguarding the personal information of its employees, clients, contractors, and suppliers. By adhering to this Data Breach Response Plan, the company ensures that it is prepared to respond swiftly and effectively to data breaches, minimising the impact on individuals and maintaining compliance with data protection regulations.