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Finance Director
1.3 Finance
08. Customer Encrypted Data (CED)
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13.08 Customer Encrypted Data:
1. The Customer as the Data Controller own their own business data and have the right to access their own data at any time and for any purpose.   The Application Service Provider as the Data Processor shall use its best endevours to assist the Customer to access the Customers own business data.
2. When the Application Service Provider sends out the service fee invoice on the first of each month, that invoice includes a link to the Customer Encrypted Data (CED) dashboard.   The Customer may use that link to selectively cause any set of business data to be downloaded to a local computer using encryption.   This procedure has no operational benefit and so it is classified as additional to the financial statement.
3. To comply with Data Protection regulations, all business data is always encrypted when at rest and when being communicated.   Business data downloaded by the Customer is in the form of a password protected encrypted ZIP file - a ZIP file utility is needed to access the business data.   A person is appointed by the Customer to be shown the monthly password needed to view the business data.
4. This procedure may be used to replace legacy download services that are no longer compliant with Data protection regulations.   A Customer as the Data Controller takes fully responsibility for the life cycle and security of all downloaded business data.   This includes reportable data breach notification to the Information Commissioners Office.

Customer Encrypted Data (CED) Download Dashboard:
1. Invoice link to CED Download Dashboard.
2. Dashboard shows a data diagram with active links for each class of data.
3. Each class of data is downloaded as a password protected encrypted ZIP file.   A ZIP file of all business data would be physically too big to download, so it must be downloaded in logical parts.
4. The approved person is notified of the monthly ZIP password.   Only one set of business data is available for download and that set is periodically (monthly) replaced.   The Customer manages who may access the CED decryption password.

Data Fragmentation:
1. Business data is naturally fragmented by application service.
2. The Personnel Application Service is distinct from the Customer Relationship Management Application Service.
3. The dashboard shows a diagram of how application is fragmented by data object.
4. Click on any diagram link to download that set of business data.
5. Business data may be archive by year and each years worth of business data may be separatly downloaded.   Once business data is downloaded for an archived year, then that data may not need to be downloaded again because it cannot change.

Document Control:
1. Document Title: Customer Encrypted Data.
2. Reference: 161308.
3. Keywords: Customer Encrypted Data, Bespoke Application Service, Application Service Provider.
4. Description: Customer Encrypted Data owned by the Customer may be encrypted and downloaded. This document does not provide legal or financial advice.
5. Privacy: Public information service to who it may concern.
6. Issued: 11 Feb 2017.
7. Edition: 1.1.