Data Protection Policy

Data protection principles

Otis Air Conditioning is committed to processing data in accordance with its responsibilities under the Cayman Islands Data Protection Law (DPL).

The DPL is centred around eight data protection principles that set out a framework within which personal data is processed.

1. Fair and Lawfulness Use
2. Purpose Limitation
3. Data Minimization
4. Data Accuracy
5. Storage Limitation
6. Respect for the Individual’s rights
7. Security – Integrity and Confidentiality
8. International Transfers

General provisions

1. This policy applies to all personal data processed by Otis Air Conditioning.
2. The Responsible Person shall take responsibility for Otis Air Conditioning’s ongoing compliance with this policy.
3. This policy shall be reviewed at least annually.

Lawful, fair and transparent processing

1. To ensure its processing of data is lawful, fair and transparent, Otis Air Conditioning shall maintain a Register of Systems.
2. The Register of Systems shall be reviewed at least annually.
3. Individuals have the right to access their personal data and any such requests made to Otis Air Conditioning shall be dealt with in a timely manner.

Lawful purposes

1. All data processed by Otis Air Conditioning must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
2. Otis Air Conditioning shall note the appropriate lawful basis in the Register of Systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Otis Air Conditioning’s systems.

Data minimisation

1. Otis Air Conditioning shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Accuracy

1. Otis Air Conditioning shall take reasonable steps to ensure personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

Archiving / removal

1. To ensure that personal data is kept for no longer than necessary, Otis Air Conditioning shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
2. The archiving policy shall consider what data should/must be retained, for how long, and why.

Security

1. Otis Air Conditioning shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
3. When personal data is deleted this should be done safely such that the data is irrecoverable.
4. Appropriate back-up and disaster recovery solutions shall be in place.

Breach

In the, unlikely, event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Otis Air Conditioning shall promptly assess the risk to people’s rights and freedoms.