Policy prepared by:
Marco Vincenzo Sicuro
01 April 2020
Policy became operation on:
01 April 2020
Next review date: 01 January 2021
The firm needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.
This data protection policy ensures that we:
Comply with data protection law and follow good practice
Protects the rights of staff, customers and partners
Is open about how it stores and processes individuals’ data
Protects itself from the risks of a data breach
The Data Protection Act 1998 describes how we must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The Data Protection Act is underpinned by eight important principles. These say that personal data must:
1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
This policy applies to:
It applies to all data that we hold relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998.
This can include:
…plus any other information relating to individuals
This policy helps to protect the firm from some very real data security risks, including:
Everyone who works for the firm has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
However, these people have key areas of responsibility:
The Board of Directors is ultimately responsible for ensuring that the firm meets its legal obligations.
The Compliance Officer is responsible for:
Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
The IT Manager is responsible for:
The Marketing Manager is responsible for:
The only people able to access data covered by this policy should be those who need it for their work.
Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
The firm will provide training to all employees to help them understand their responsibilities when handling data.
Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
In particular, strong passwords must be used and they should never be shared.
Personal data should not be disclosed to unauthorised people, either within the company or externally.
Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or the Data Controller.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
Personal data is of no value to the firm unless we can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
The law requires the firm to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort the firm should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
The firm will make it easy for data subjects to update the information it holds about them. For instance, via the company website.
Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
All individuals who are the subject of personal data held by the firm are entitled to:
Ask what information we hold about them and why.
Ask how to gain access to it.
Be informed how to keep it up to date.
Be informed how the firm is meeting its data protection obligations.
If an individual contacts the firm requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the data controller at [email address]. The data controller can supply a standard request form, although individuals do not have to use this.
Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, the firm will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the firm’s legal advisers where necessary.
The firm aims to ensure that individuals are aware that their data is being processed, and that they understand:
To these ends, the firm has a privacy statement, setting out how data relating to individuals is used by the company.
This is available on request. A version of this is also available on our website