Privacy Policy

Who we are

Poseidon Dive Center Ao Nang

What personal data we collect and why we collect it

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Analytics

Who we share your data with

We maintain direct control over as many processes as we can. As necessary in connection with the above purposes, your personal data may be transferred to the Board of Trustees or our authorized third-party service providers and partners. We conscientiously select and review authorized third parties when possible and review their privacy and security policies. These authorized third parties may be engaged in, among other things, the processing of donations, technology support, outreach campaigns, or research projects carried out in connection with our mission. Limited members of Privacy International staff or the staff working for these third parties may also access and otherwise process your personal data in connection with their job responsibilities or contractual obligations.

Some of these personnel and authorized third parties (for example payment processors) may transfer data outside Thailand (“TH”) or European Union (“EU”). We take appropriate steps to ensure that data remains within jurisdictions with adequate protections for personal data and ensure that recipients of personal data from us are bound to duties of confidentiality, where relevant or appropriate. Where this is not possible, we rely on data minimization, the selection of trusted companies with privacy policies and auditable processes which we have reviewed and seek to ensure that there are adequate safeguards in place for protecting transferred data, for example Standard Contractual Clauses. For more information on the safeguards for transfer in a particular operation please contact us. We may also be required to disclose or otherwise process your personal data in the context of a regulatory audit to which we may be subject from time to time.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

Your contact information

Will never be shared with any third party and is safe with us. We do not sell, rent or lease personal data.

How we protect your data

Personal data shall be subject to additional safeguards to ensure this data is processed securely. For example, we work hard to ensure data is encrypted when in transit and storage, and access to this data will be strictly limited to a minimum number of individuals and subject to confidentiality commitments.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to any of our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. When possible, encryption is used, both in transit and storage. Access controls within the organisation limit who may access information.

What data breach procedures we have in place

Our Privacy Officer will investigate and deal with privacy breaches in accordance with the following Data Breach
1 Background
Data security breaches are increasingly common occurrences whether caused through human error
or via malicious intent. As the amount of data and information grows and technology develops,
there are new ways by which data can be breached. The Council needs to have in place a robust and
systematic process for responding to any reported data security breach, to ensure it can act
responsibly and protect personal data which it holds.
2 Aim
The aim of this policy is to standardize the Council’s response to any data breach and ensure that they are appropriately logged and managed in accordance with the law and best practice, so that:
  • incidents are reported swiftly and can be properly investigated
  • incidents are dealt with in a timely manner and normal operations restored
  • incidents are recorded and documented
  • the impact of the incident is understood, and action is taken to prevent further damage
  • the ICO and data subjects are informed as required in more serious cases
  • incidents are reviewed, and lessons learned
3 Definition
Article 4 (12) of the General data protection Regulation (“GDPR”) defines a data breach as: “a breach of security leading to the unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.” Poseidon Dive Center Council (‘the Council’) is obliged under the GDPR to act in respect of such data breaches. This procedure sets out how the Council will manage a report of a suspected data security breach.
The aim is to ensure that where data is misdirected, lost, hacked or stolen,
inappropriately accessed or damaged, the incident is properly investigated and reported, and any necessary action is taken to rectify the situation.
A data security breach can come in many forms, but the most common are as follows:
  • Loss or theft of paper or other hard copy
  • Data posted, e mailed or faxed to the incorrect recipient
  • Loss or theft of equipment on which data is stored inappropriate sharing or dissemination
  • Staff accessing information to which they are not entitled
  • Hacking, malware, data corruption
  • Information is obtained by deception or “blagging”
  • Equipment failure, fire or flood
  • Unescorted visitors accessing data
  • Non secure disposal of data
In any situation where staff are uncertain whether an incident constitutes a breach of security, either report it to the Data Protection Officer (DPO) or the Senior Information Risk Owner (SIRO). If there are IT issues, such as the security of the network being compromised, IT should be informed immediately.
4 Scope
This Council wide policy applies to all Council an information, regardless of format, and is applicable to all officers, members, visitors, contractors, partner organizations and data processors acting on behalf of the Council. It is to be read in conjunction with the Council’s Information Security Policy.
5 Responsibilities
Information users The GDPR applies to both Data Controllers (the Council itself) and to Data Handlers. Therefore, all information users are responsible for reporting actual, suspected, threatened or potential information security incidents and for assisting with investigations as required, particularly if urgent action must be taken to prevent further damage. Managers Heads of Department are responsible for ensuring that staff in their area act in compliance with this policy and assist with investigations as required.
Lead Responsible Officers
(DPO, SIRO, S 151 and MO) will be responsible for overseeing management
of the breach in accordance with the Data Breach Management Plan. Suitable further delegation may be appropriate in some circumstances.
6 Reporting a Breach Internal
Suspected data security breaches should be reported promptly to
the DPO as the primary point of contact on +66980719035, email: webmaster@poseidon-krabi.com. The report must contain full and accurate details of the incident including who is reporting the incident [and what classification of data is involved]. The incident report form should be completed as part of the reporting process. See Appendix 1.
Once a data breach has been reported an initial
assessment will be made to establish the severity of the breach.
All data security breaches will be centrally logged by the DPO to ensure appropriate oversight in the types and frequency of confirmed incidents for management and reporting purposes.
External
Article 33 of the GDPR requires the Council as data controller to notify the ICO only when the breach “is likely to result in a risk to the freedoms and rights of natural persons”. Such a breach also must be communicated to the data subject (with certain exceptions). Notification must be made “without
undue delay” and within 72 hours of becoming aware of it. If the Council fails to do this, it must explain the reason for the delay. Article 33(5) requires that the Council must maintain documentation on data breaches, their nature and remedial action taken.
A report to the ICO must contain information as to the nature of the breach, categories of data, number of data records, number of people affected, nam
e and contact details of DPO, likely consequences of the breach and action taken.
7 Data Breach Management Plan
The Council’s response to any reported data security breach will involve the following four elements.
A. Containment and Recovery
B. Assessment of Risks
C. Consideration of Further Notification
D. Evaluation and Response
Each of these four elements will need to be conducted in accordance with the checklist. An activity log recording the timeline of the incident management should also be completed.
NB. This reflects current guidance from the ICO, which is likely to change.
8 Disciplinary
Officers, members, contractors, visitors or partner organizations who act in breach of this policy may be subject to disciplinary procedures or other appropriate sanctions.
9 Review
This document shall be subject to annual review by the DPO/SIRO and MO.
10 References
• The GDPR https://gdpr-info.eu/
ICO GUIDANCE ON DATA BREACHES
https://ico.org.uk/media/fororganisations/documents/1562/guidance_on_data_security_
breach_management.pdf
Appendix 1 Data Breach Reporting Template
Report by:
Name:
Job Title:
Service:
Date:
1.
Summary of event and
circumstances
Who, what, when, who etc.
2.
Type and amount of personal
data
Title of document(s)-what information is included-name, contact details, financial, sensitive or special category data.
3. Action taken by recipient
4.
Action taken to retrieve data and respond to breach
5. Procedure/policy in place to minimize risk Communication, secure storage, sharing, exchange.
6.
Breach of policy/procedure
by officer/member
Has there been a breach of policy and has appropriate
management action been taken?
7.
Details of notification to data subject.
Complaint received?
Has data subject been notified? If not, explain why. What advice has been offered?
8. Date of most recent training by staff/ Councillor involved
Details of Data Protection
training provided.
9.
Risk assessment and changes need to prevent further data loss
10. Conclusions and learning points

What third parties we receive data from

We may also point from our websites to other internet services that do use cookies. Our payment processors, for example, will place cookies as well. This is also the case with multi-media services, and with the links that we post on our Twitter and Facebook accounts.

Social Media

We use social media and social networking services to advance our work. These applications require the use of third party service providers. Notably, we have a Facebook page, Twitter feed, articles published on Medium, and a YouTube channel.

The Facebook page is administered by Facebook, in accordance with Facebook’s Data Policy available here, and is accessible by Facebook users who have already consented to Facebook’s Data Policy. The Group page is managed by Privacy International staff members. We do not export information on our followers from the Facebook platform.

The Twitter account we use is administered by Twitter, in accordance with Twitter’s Privacy Policy available here.

The YouTube channel is administered by YouTube and Google, in accordance with their privacy policy available here.

The same applies to the Google+ Page, in accordance with their privacy policy available here.

The Pinterest Page we use is administered by Pinterest, in accordance with their privacy policy available here.

The Instagram Page we use is administered by Instagram, in accordance with their privacy policy available here.

We use direct messaging over social media on occasion, when individuals and organizations contact us on Facebook by leaving messages in our Inbox or by sending us Direct Messages on Twitter.