Last updated October 11, 2018
Who we are
You have been directed here from an automotive retailer and we understand that privacy and security of your information is important. This Privacy Notice explains what information we collect from you when using this website and why. We will only use your data for the purposes outlined below. See below under Other Useful Information for more details of our company and the Data Controller.
What information is collected
Information about your name, date of birth, address, gender, marital/family status and contact details (such as phone numbers and an email address).
Your current and previous address details (for up to 3 years), plus employment and salary.
The information you enter on this website will be saved as you input it in order to provide quick and accurate feedback. This mechanism ensures that the data we collect from you is of the highest quality, helping us provide you with the very best levels of service.
Why is this information required
All information entered is securely provided to the retailer to contact you to discuss your purchase and finance, which we store on their behalf. The retailer may need to contact you for more information before your information can be passed on to a lender as part of a formal application. Your retailer will be able to advise you fully of this process and answer any questions you might have.
The information you provide us with in order to offer these services is not used to fulfill a contractual or binding agreement with us.
A failure to provide accurate and relevant data will mean that you are unable to benefit from some or all of the services.
Please note that these other parties detailed above are data controllers and will have their own applicable policies for their handling of your data. Please refer to them directly and/or their websites for more information.
Who else might your information be shared with
We use third party user tracking services on our forms (Google Analytics), but when you visit our website, your IP address is anonymised before transmission to this service. This means we do not provide them with any personal data which can be attributed to a natural person.
We don’t in any circumstances transmit any personal data outside of the European Economic Area. Our data centres are in the UK and we specify EEA for cloud services (Google/Amazon Web Services).
Sharing your information within our company
We share the information that you provide to us with our staff so that we can provide our products and services to you.
We may share the information that you provide to us with other companies and other websites that we operate.
Sharing your information with third parties
We may share your data with selected third parties. For example, we may share your information with:
Internet hosting providers to host the website, related infrastructure, services and applications
Contact management systems to send emails, instant messages, social media messages and SMS messages
There are certain exceptional circumstances in which we may disclose your information to third parties. This would be where we believe that the disclosure is:
Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings
Necessary to protect the safety of our employees, our property or the public
Necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction.
Proportionate as part of a merger, business or asset sale, in the event that this happens we will share your information with the prospective seller or buyer involved
How we secure your data
All the data you send to us is encrypted during transmission using modern, industry standard techniques such as HTTPS.
All personal data transmitted to or from third parties is encrypted during transmission as per the data you send to us.
Data is stored on servers in a data centre to which access is restricted and audited. Remote access to that data is restricted to our website services, back office administration systems and authorised personnel responsible for the maintenance and administration of those servers.
Emails that we send to you, in terms of your personal data, will only ever contain your email address and your first name.
We will never email you with any sensitive data or passwords. We will never ask you for your full password over the phone. No emails are sent that include information about your credit search results.
We may use two factor or multi-factor authentication to help confirm your identity and prevent unauthorised access to your data.
How we store and process your data
We process your data where necessary for our legitimate interests as further outlined in this Privacy Notice.
The information will be stored and may be used as part of a Motor Credit Check or other finance enquiry/application should your purchase proceed through the same retailer. This is to avoid you entering the same data all over again, but note that if more information is needed you will be advised separately.
In the event we identify a problem with our service, or you highlight a problem to us, your data may be reviewed and/or processed in order to help diagnose and/or resolve the identified problem.
Your data may be used in aggregate/statistically for the purposes of tracking the take up of and improvement of our products.
We do not send any marketing information to you, nor sell any part of your data to third parties.
How long we keep your data for – as processor
We store your data for as long as the Data Controller instructs us to, unless we are provided with an earlier request to delete your data.
What rights do you have in respect of your personal information?
You have the right to be informed
We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this policy to do just that, but if you have any questions or require more specific information, you can get in touch using our website.
You have the right to access your personal data
You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:
Why we have been using your information
What categories of information we were using
Who we have shared the information with
How long we envisage holding your information
In order to maintain the security of your information, we will have to verify your identity before we provide you with a copy of the information we hold.
The first copy of your information that you request from us will be provided free of charge, if you require further copies we may charge an administrative fee to cover our costs.
You have the right to correct any inaccurate or incomplete personal data
Where you have requested a copy of the information we hold about you, you may notice that there are inaccuracies in the records, or that certain parts are incomplete. If this is the case you can contact us so that we can correct our records.
You have the right to be forgotten
There may be times where it is no longer necessary for us to hold personal information about you. This could be if:
The information is no longer needed for the original purpose that we collected it for
You withdraw your consent for us to use the information (and we have no other legal reason to keep using it)
You object to us using your information and we have no overriding reason to keep using it
We have used your information unlawfully
We are subject to a legal requirement to delete your information
In those situations you have the right to have your personal data deleted. If you believe one of these situations applies to you, please get in touch using our website.
You have the right to have a copy of your data transferred to you or a third party in a compatible format
Also known as data portability, you have the right to obtain a copy of your personal data for your own purposes. This right allows you to move, copy or transfer your personal data more easily from one IT system to another, in a safe and secure way.
If you would like us to transfer a copy of your data to you or another organisation in a structured, commonly used and machine-readable format, please contact us. There is no charge for you exercising this right.
You have the right to object to us using your information for our own legitimate interests
Sometimes, we use your personal information to achieve goals that will help us as well as you. This includes:
When we tell you about products or services that are similar to ones that you have already bought
When we use you information to help us make our business better
When we contact you to interact, communicate or let you know about changes we are making
We aim to always ensure that your rights and information are properly protected. If you believe that the way we are using your data is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal data for these purposes.
In order to exercise your right to object to our use of your data for the purposes above, please contact us.
You have the right to restrict how we use your personal data
You have the right to ask us to stop using your personal data in any way other than simply keeping a copy of it. This right is available where:
You have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify this
You have objected to us using your information for our own legitimate interests and we are in the process of considering your objection
We have used your information in an unlawful way, but you do not want us to delete your data
We no longer need to use the information, but you need it for a legal claim
If you believe any of these situations apply, please contact us.
You have rights related to automated-decision making and profiling
Other useful information
The automotive retailer is the Data Controller and duly registered in the UK with the Information Commissioner’s Office (ICO) under Fairview Trade Sales.
The Data Controller is Fairview Trade Sales. Their registered address is 4, 5 & 6 Under Cardiff Road, Bargoed, Mid Glamorgan, CF81 8WZ and can be contacted by email at email@example.com or phone on 01443831670.
The accuracy of your information is important. If you change your email address, or become aware that any of the other information we hold is inaccurate or out of date, or need to request a copy of the information held about you, please use the contact details above.
Lodging a complaint with the Information Commissioner’s Office
Under Data Protection Regulation, you have the right to report a concern with a Supervisory Authority which in the United Kingdom is the Information Commissioner’s Office.
You can report concerns via the ICO website.
- Information of Card Security Policy
Fairview Trade Sales 25/05/18
Information Security Policy 3
1. Network Security 4
2. Acceptable Use Policy 4
3. Protect Stored Data 4
4. Information Classification 5
5. Access to the Sensitive Cardholder Data 5
6. Physical Security 6
7. Protect Data in Transit 6
8. Disposal of Stored Data 7
9. Security Awareness and Procedures 7
10. Credit Card (PCI) Security Incident Response Plan 8
11. Transfer of Sensitive Information Policy 12
12. User Access Management 12
13. Access Control Policy 13
Appendix A – Agreement to Comply Form – Agreement to Comply With Information Security Policies 15
Appendix B – List of Devices 16
This Policy document encompasses all aspects of security surrounding confidential company information and must be distributed to all company employees. All company employees must read this document in its entirety and sign the form confirming they have read and fully understand this policy. This document will be reviewed and updated by Management on an annual basis or when relevant to include newly developed security standards into the policy and re-distributed to all employees and contractors where applicable.
Information Security Policy
Fairview Trade Sales handles sensitive cardholder information daily. Sensitive Information must have adequate safeguards in place to protect the cardholder data, cardholder privacy, and to ensure compliance with various regulations,along with guarding the future of the organisation.
Fairview Trade Sales commits to respecting the privacy of all its customers and to protecting any customer data from outside parties. To this end management are committed to maintaining a secure environment in which to process cardholder information so that we can meet these promises.
Employees handling sensitive cardholder data should ensure:
l Handle Company and cardholder information in a manner that fits with their sensitivity and classification;
l Limit personal use of Fairview Trade Sales information and telecommunication systems and ensure it doesn’t interfere with your job performance;
l Fairview Trade Sales reserves the right to monitor, access, review, audit, copy, store, or delete any electronic communications, equipment, systems and network traffic for any purpose;
l Do not use e-mail, internet and other Company resources to engage in any action that is offensive, threatening, discriminatory, defamatory, slanderous, pornographic, obscene, harassing or illegal;
l Do not disclose personnel information unless authorised;
l Protect sensitive cardholder information;
l Keep passwords and accounts secure;
l Request approval from management prior to establishing any new software or hardware, third party connections, etc.;
l Do not install unauthorised software or hardware, including modems and wireless access unless you have explicit management approval;
l Always leave desks clear of sensitive cardholder data and lock computer screens when unattended;
l Information security incidents must be reported, without delay, to the individual responsible for incident response locally – Please find out who this is.
We each have a responsibility for ensuring our company’s systems and data are protected from unauthorised access and improper use. If you are unclear about any of the policies detailed herein you should seek advice and guidance from your line manager.
1. Network Security
A high-level network diagram of the network is maintained and reviewed on a yearly basis. The network diagram provides a high level overview of the cardholder data environment (CDE), which at a minimum shows the connections in and out of the CDE.Critical system components within the CDE, such as POS devices, databases, web servers, etc., and any other necessary payment components, as applicable should also be illustrated.
In addition, ASV should be performed and completed by a PCI SSC Approved Scanning Vendor, where applicable. Evidence of these scans should be maintained for a period of 18 months.
2. Acceptable Use Policy
Management’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to Fairview Trade Sales established culture of openness, trust and integrity. Management is committed to protecting the employees, partners and the Company from illegal or damaging actions, either knowingly or unknowingly by individuals. Fairview Trade Sales will maintain an approved list of technologies and devices and personnel with access to such devices as detailed in Appendix B.
• Employees are responsible for exercising good judgement regarding the reasonableness of personal use.
• Employees should take all necessary steps to prevent unauthorised access to confidential data which includes card holder data.
• Keep passwords secure and do not share accounts. Authorised users are responsible for the security of their passwords and accounts.
• All PCs, laptops and workstations should be secured with a password-protected screensaver with the automatic activation feature.
• All POS and PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.
• The List of Devices in Appendix B will be regularly updated when devices are modified, added or decommissioned. A stocktake of devices will be regularly performed and devices inspected to identify any potential tampering or substitution of devices.
• Users should be trained in the ability to identify any suspicious behaviour where any tampering or substitution may be performed. Any suspicious behaviour will be reported accordingly.
• Information contained on portable computers is especially vulnerable, special care should be exercised.
• Postings by employees from a Company email address to newsgroups should contain a disclaimer stating that the opinions expressed are strictly their own and not necessarily those of Fairview Trade Sales, unless posting is in the course of business duties.
• Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain viruses, e-mail bombs, or Trojan horse code.
3. Protect Stored Data
• All sensitive cardholder data stored and handled by Fairview Trade Sales and its employees must be securely protected against unauthorised use at all times. Any sensitive card data that is no longer required by Fairview Trade Sales for business reasons must be discarded in a secure and irrecoverable manner.
• If there is no specific need to see the full PAN (Permanent Account Number), it has to be masked when displayed.
• PAN’S which are not protected as stated above should not be sent to the outside network via end user messaging technologies like chats,ICQ messenger etc.,
It is strictly prohibited to store:
1. The contents of the payment card magnetic stripe (track data) on any media whatsoever.
2. The CVV/CVC (the 3 or 4 digit number on the signature panel on the reverse of the payment card) on any media whatsoever.
3. The PIN or the encrypted PIN Block under any circumstance.
4. Information Classification
Data and media containing data must always be labelled to indicate sensitivity level.
• Confidential data might include information assets for which there are legal requirements for preventing disclosure or financial penalties for disclosure, or data that would cause severe damage to Fairview Trade Sales if disclosed or modified. Confidential data includes cardholder data.
• Internal Use data might include information that the data owner feels should be protected to prevent unauthorised disclosure.
• Public data is information that may be freely disseminated.
5. Access to the Sensitive Cardholder Data
All Access to sensitive cardholder should be controlled and authorised. Any job functions that require access to cardholder data should be clearly defined.
• Any display of the card holder should be restricted at a minimum to the first 6 and the last 4 digits of the cardholder data.
• Access to sensitive cardholder information such as PAN’s, personal information and business data is restricted to employees that have a legitimate need to view such information.
• No other employees should have access to this confidential data unless they have a genuine business need.
• If cardholder data is shared with a Service Provider (3rd party) then a list of such Service Providers will be maintained as detailed in Appendix C.
• Fairview Trade Sales will ensure a written agreement that includes an acknowledgement is in place that the Service Provider will be responsible for the for the cardholder data that the Service Provider possess.
• Fairview Trade Sales will ensure that a there is an established process, including proper due diligence is in place, before engaging with a Service provider.
• The Company will have a process in place to monitor the PCI DSS compliance status of the Service provider.
6. Physical Security
Access to sensitive information in both hard and soft media format must be physically restricted to prevent unauthorised individuals from obtaining sensitive data.
• Media is defined as any printed or handwritten paper, received faxes, floppy disks, back-up tapes, computer hard drive, etc.
• Media containing sensitive cardholder information must be handled and distributed in a secure manner by trusted individuals.
• Visitors must always be escorted by a trusted employee when in areas that hold sensitive cardholder information.
• Procedures must be in place to help all personnel easily distinguish between employees and visitors, especially in areas where cardholder data is accessible. “Employee” refers to full-time and part-time employees, temporary employees and personnel, and consultants who are “resident” on Fairview Trade Sales sites. A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to physically enter the premises for a short duration, usually not more than one day.
• A list of devices that accept payment card data should be maintained.
• The list should include make, model and location of the device.
• The list should have the serial number or a unique identifier of the device
• The list should be updated when devices are added, removed or relocated
• POS devices surfaces are periodically inspected to detect tampering or substitution.
• Personnel using the devices should be trained and aware of handling the POS devices
• Personnel using the devices should verify the identity of and=y third party personnel claiming to repair or run maintenance tasks on the devices, install new devices or replace devices.
• Personnel using the devices should be trained to report suspicious behaviour and indications of tampering of the devices to the appropriate personnel. Fairview Trade Sales sites. A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to enter the premises for a short duration, usually not more than one day.
• Strict control is maintained over the external or internal distribution of any media containing card holder data and has to be approved by management
• Strict control is maintained over the storage and accessibility of media
• All computer that store sensitive cardholder data must have a password protected screensaver enabled to prevent unauthorised use.
7. Protect Data in Transit
All sensitive cardholder data must be protected securely if it is to be transported physically or electronically.
• Card holder data (PAN, track data, etc.) must never be sent over the internet via email, instant chat or any other end user technologies.
• If there is a business justification to send cardholder data via email or by any other mode then it should be done after authorisation and by using a strong encryption mechanism (i.e. – AES encryption, PGP encryption,IPSEC, etc.).
• The transportation of media containing sensitive cardholder data to another location must be authorised by management, logged and inventoried before leaving the premises. Only secure courier services may be used for the transportation of such media. The status of the shipment should be monitored until it has been delivered to its new location.
8. Disposal of Stored Data
• All data must be securely disposed of when no longer required by Fairview Trade Sales, regardless of the media or application type on which it is stored.
• An automatic process must exist to permanently delete on-line data, when no longer required.
• All hard copies of cardholder data must be manually destroyed when no longer required for valid and justified business reasons. A quarterly process must be in place to confirm that all non-electronic cardholder data has been appropriately disposed of in a timely manner.
• Fairview Trade Sales will have procedures for the destruction of hardcopy (paper) materials. These will require that all hardcopy materials are crosscut shredded, incinerated or pulped so they cannot be reconstructed.
• Fairview Trade Sales will have documented procedures for the destruction of electronic media. These will require:
o All cardholder data on electronic media must be rendered unrecoverable when deleted e.g. through degaussing or electronically wiped using military grade secure deletion processes or the physical destruction of the media;
o If secure wipe programs are used, the process must define the industry accepted standards followed for secure deletion.
• All cardholder information awaiting destruction must be held in lockable storage containers clearly marked “To Be Shredded” – access to these containers must be restricted.
9. Security Awareness and Procedures
The policies and procedures outlined below must be incorporated into company practice to maintain a high level of security awareness. The protection of sensitive data demands regular training of all employees and contractors.
• Review handling procedures for sensitive information and hold periodic security awareness meetings to incorporate these procedures into day to day company practice.
• Distribute this security policy document to all company employees to read. It is required that all employees confirm that they understand the content of this security policy document by signing an acknowledgement form (see Appendix A).
• All employees that handle sensitive information will undergo background checks (such as criminal and credit record checks, within the limits of the local law) before they commence their employment with the Company.
• All third parties with access to credit card account numbers are contractually obligated to comply with card association security standards (PCI/DSS).
• Company security policies must be reviewed annually and updated as needed.
10. Credit Card (PCI) Security Incident Response Plan
• Fairview Trade Sales PCI Security Incident Response Team (PCI Response Team) is comprised of the Information Security Officer and Merchant Services. Fairview Trade Sales PCI security incident response plan is as follows:
1. Each department must report an incident to the Information Security Officer (preferably) or to another member of the PCI Response Team.
2. That member of the team receiving the report will advise the PCI Response Team of the incident.
3. The PCI Response Team will investigate the incident and assist the potentially compromised department in limiting the exposure of cardholder data and in mitigating the risks associated with the incident.
4. The PCI Response Team will resolve the problem to the satisfaction of all parties involved, including reporting the incident and findings to the appropriate parties (credit card associations, credit card processors, etc.) as necessary.
5. The PCI Response Team will determine if policies and processes need to be updated to avoid a similar incident in the future, and whether additional safeguards are required in the environment where the incident occurred, or for the institution.
Fairview Trade Sales PCI Security Incident Response Team (or equivalent in your organisation):
Information Security Officer
Collections & Merchant Services
Information Security PCI Incident Response Procedures:
• A department that reasonably believes it may have an account breach, or a breach of cardholder information or of systems related to the PCI environment in general, must inform Fairview Trade Sales PCI Incident Response Team. After being notified of a compromise, the PCI Response Team, along with other designated staff, will implement the PCI Incident Response Plan to assist and augment departments’ response plans.
Incident Response Notification
Escalation Members (or equivalent in your company):
Escalation – First Level:
Information Security Officer Controller
Executive Project Director for Credit Collections and Merchant Services Legal Counsel
Director of Fairview Trade Sales Communications
Escalation – Second Level:
Fairview Trade Sales President
Auxiliary members as needed
External Contacts (as needed)
Merchant Provider Card
Internet Service Provider (if applicable)
Internet Service Provider of Intruder (if applicable) Communication Carriers (local and long distance) Business Partners
External Response Team as applicable (CERT Coordination Centre1, etc.) Law Enforcement Agencies as applicable inn local jurisdiction
In response to a systems compromise, the PCI Response Team and designees will:
1. Ensure compromised system/s is isolated on/from the network.
2. Gather, review and analyse the logs and related information from various central and local safeguards and security controls
3. Conduct appropriate forensic analysis of compromised system.
4. Contact internal and external departments and entities as appropriate.
5. Make forensic and log analysis available to appropriate law enforcement or card industry security personnel, as required.
6. Assist law enforcement and card industry security personnel in investigative processes, including in prosecutions.
How to notify Elavon in the event of an incident
• E-mail: #ADCqueries-GB@elavon.com
• Phone: 0 1923 651 622
• E-mail: #ADCqueries-IE@elavon.com
• Phone: 0402 25322
6. Other Countries:
11. Transfer of Sensitive Information Policy
• All third-party companies providing critical services to Fairview Trade Sales must provide an agreed Service Level Agreement.
• All third-party companies providing hosting facilities must comply with the Company’s Physical Security and Access Control Policy.
• All third-party companies which have access to Card Holder information must
1. Adhere to the PCI DSS security requirements.
2. Acknowledge their responsibility for securing the Card Holder data.
3. Acknowledge that the Card Holder data must only be used for assisting the completion of a transaction, supporting a loyalty program, providing a fraud control service or for uses specifically required by law.
4. Have appropriate provisions for business continuity in the event of a major disruption, disaster or failure.
5. Provide full cooperation and access to conduct a thorough security review after a security intrusion by a Payment Card industry representative, or a Payment Card industry approved third party.
12. User Access Management
• Access to Fairview Trade Sales is controlled through a formal user registration process beginning with a formal notification from HR or from a line manager.
• Each user is identified by a unique user ID so that users can be linked to and made responsible for their actions. The use of group IDs is only permitted where they are suitable for the work carried out.
• There is a standard level of access; other services can be accessed when specifically authorised by HR/line management.
• The job function of the user decides the level of access the employee has to cardholder data
• A request for service must be made in writing (email or hard copy) by the newcomer’s line manager or by HR. The request is free format, but must state:
Name of person making request;
Job title of the newcomers and workgroup;
Services required (default services are: MS Outlook, MS Office and Internet access).
• Each user will be given a copy of their new user form to provide a written statement of their access rights, signed by an IT representative after their induction procedure. The user signs the form indicating that they understand the conditions of access.
• Access to all Fairview Trade Sales systems is provided by IT and can only be started after proper procedures are completed.
• As soon as an individual leaves Fairview Trade Sales employment, all his/her system logons must be immediately revoked.
• As part of the employee termination process HR (or line managers in the case of contractors) will inform IT operations of all leavers and their date of leaving.
13. Access Control Policy
• Access Control systems are in place to protect the interests of all users of Fairview Trade Sales computer systems by providing a safe, secure and readily accessible environment in which to work.
• Fairview Trade Sales will provide all employees and other users with the information they need to carry out their responsibilities in an as effective and efficient manner as possible.
• Generic or group IDs shall not normally be permitted, but may be granted under exceptional circumstances if sufficient other controls on access are in place.
• The allocation of privilege rights (e.g. local administrator, domain administrator, super-user, root access) shall be restricted and controlled, and authorisation provided jointly by the system owner and IT Services. Technical teams shall guard against issuing privilege rights to entire teams to prevent loss of confidentiality.
• Access rights will be accorded following the principles of least privilege and need to know.
• Every user should attempt to maintain the security of data at its classified level even if technical security mechanisms fail or are absent.
• Users electing to place information on digital media or storage devices or maintaining a separate database must only do so where such an action is in accord with the data’s classification.
• Users are obligated to report instances of non-compliance to Fairview Trade Sales CISO.
• Access to Fairview Trade Sales IT resources and services will be given through the provision of a unique Active Directory account and complex password.
• No access to any of Fairview Trade Sales IT resources and services will be provided without prior authentication and authorisation of a user’s Fairview Trade Sales Windows Active Directory account.
• Password issuing, strength requirements, changing and control will be managed through formal processes. Password length, complexity and expiration times will be controlled through Windows Active Directory Group Policy Objects.
• Access to Confidential, Restricted and Protected information will be limited to authorised persons whose job responsibilities require it, as determined by the data owner or their designated representative. Requests for access permission to be granted, changed or revoked must be made in writing.
• Users are expected to become familiar with and abide by Fairview Trade Sales policies, standards and guidelines for appropriate and acceptable usage of the networks and systems.
• Access for remote users shall be subject to authorisation by IT Services and be provided in accordance with the Remote Access Policy and the Information Security Policy. No uncontrolled external access shall be permitted to any network device or networked system.
• Access to data is variously and appropriately controlled according to the data classification levels described in the Information Security Management Policy.
• Access control methods include logon access rights, Windows share and NTFS permissions, user account privileges, server and workstation access rights, firewall permissions, IIS intranet/extranet authentication rights, SQL database rights, isolated networks and other methods as necessary.
• A formal process shall be conducted at regular intervals by system owners and data owners in conjunction with IT Services to review users’ access rights. The review shall be logged and IT Services shall sign off the review to give authority for users’ continued access rights.