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Affino Data Breach Policy

Under GDPR from May 2018 there is a breach notification policy across the whole of Affino.




Comrz Ltd trading as Affino are required to notify the ICO (Information Commissioners Office) within 72 hours of any relevant data security breach. Fines may occur for any that are not notified within the timescales.


Relevant breaches are those where the individual is likely to suffer some form of damage, such as identity theft or a confidentiality breach.


Internal Reporting Policy


All Affino staff members and contractors must be aware at all times on any instances that may occur that may give rise to a data protection breach.


Should a team member become aware of such a breach, this must be notified to the Line Manager, or an alternative manager should your Line Manager not be available, immediately. Your Line Manager will in turn notify the nominated Data Protection Office at Affino. This must be done immediately. In addition to notifying the Line Manager a report should be made using the form here.


The Data Protection Office is required to record all breaches within the data Security Incident Report and notify the ICO should the breach be identified as relevant to report.


When a personal data breach has occurred, the severity of the resulting risk to the individuals rights and freedoms must be established. If it is likely there will be a risk, then the ICO must be notified immediately, if the risk is unlikely it does not need to be reported. However, if the decision is made not to report the breach to the ICO, this decision will need to be justified, and therefore the reasons documented and attached to the register.


Reporting Policy to the ICO


If you need to report a breach – the process is as follows:

  • Go to – For Organisation
  • Select ‘Report a Breach’
  • Within this section, there are 2 options to choose from
  • Report a data Security Breach – Then follow instructions
    Section 55 breach – unlawful use of personal data
    Complete the relevant section
  • The ICO will report back to Affino should any further information / action be required


Reporting Policy to other persons / organisations


Affino must inform the individual concerned regarding the data breach and the action taken. This must be actioned immediately.


Affino must also decide whether other persons / organisations need to be informed of the breach. This may include the client or any other parties involved.


Action Required after any breach


All data breaches must be discussed at Senior Management level and action taken to prevent any recurrence.


These actions must be documented and monitored on an ongoing basis to ensure and such breach s not repeated.


If staff discipline is required, we would refer to HR processes.


If the ICO do require any further action, all Senior management must be advised, relevant action taken and be fully documented.


Monitoring & Training


Affino must ensure that there are monitoring processes in place to identify and prevent and data breaches.


Affino must ensure that all staff are adequately trained on data protection and on how to identify and prevent data breaches within their particular roles.


The above must be fully documented.


Markus Karlsson Profile

Markus Karlsson, CEO | Founder, Affino

20 years of digital business experience with: Audi, BBC, Casio, Diesel, EMI, MasterCard, Rovio, UBM, UMG, and now Gill, Procurement Leaders, Briefing Media, Ocean Media, and IDG. Lead consultant for digital business transformation.




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