We hold personal data about our employees, clients, suppliers and other individuals for a variety of business purposes.
This policy sets out how we seek to protect personal data and ensure that staff understand the rules governing their use of personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.
||The purposes for which personal data may be used by us:
Personnel, administrative, financial, regulatory, payroll and business development purposes.
Business purposes include the following:
– Compliance with our legal, regulatory and corporate governance obligations and good practice
– Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
– Ensuring business policies are adhered to (such as policies covering email and internet use)
– Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information
– Investigating complaints
– Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments
– Monitoring staff conduct, disciplinary matters
– Marketing our business
– Improving services
||Information relating to identifiable individuals, such as job applicants, current and former employees, agency, contract and other staff, clients, suppliers and marketing contacts.
Personal data we gather may include: individuals’ contact details, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.
|Sensitive personal data
||Personal data about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, physical or mental health or condition, criminal offences, or related proceedings—any use of sensitive personal data should be strictly controlled in accordance with this policy.
This policy applies to all staff. You must be familiar with this policy and comply with its terms.
This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.
Who is responsible for this policy?
As our Data Protection Officer, Sarah McLaughlin has overall responsibility for the day-to-day implementation of this policy.
Fair and lawful processing
We must process personal data fairly and lawfully in accordance with individuals’ rights. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.
The Data Protection Officer’s responsibilities:
- Keeping everyone updated about data protection responsibilities, risks and issues
- Reviewing all data protection procedures and policies on an annual basis
- Arranging data protection training and advice for all staff members and those included in this policy
- Answering questions on data protection from staff and stakeholders
- Responding to individuals such as clients and employees who wish to know which data is being held on them by [company name]
- Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing
Responsibilities of the IT Manager
- Ensure all systems, services, software and equipment meet acceptable security standards
- Checking and scanning security hardware and software regularly to ensure it is functioning properly
- Researching third-party services, such as cloud services the company is considering using to store or process data
Responsibilities of the Marketing Manager
- Approving data protection statements attached to emails and other marketing copy
- Addressing data protection queries from clients, target audiences or media outlets
- Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy
The processing of all data must be:
- Necessary to deliver our services
- In our legitimate interests and not unduly prejudice the individual’s privacy
- In most cases this provision will apply to routine business data processing activities.
Our Terms of Business contains a Privacy Notice to clients on data protection.
- Sets out the purposes for which we hold personal data on customers and employees
- Highlights that our work may require us to give information to third parties such as marketing agencies, solely for the purpose of email marketing and information sharing. Third parties do not have the right to share this information with any other source.
- Provides that customers have a right of access to the personal data that we hold about them
Sensitive personal data
In most cases where we process sensitive personal data we will require the data subject’s explicit consent to do this unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work or whereby our insurance dictates that we keep certain information). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.
Accuracy and relevance
We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO, Sarah McLaughlin.
Your personal data
You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required. For example, if your personal circumstances change, please inform the Data Protection Officer so that they can update your records.
You must keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third party organisations.
- Storing data securely
- In cases when data is stored on printed paper, it should be kept in a secure place where unauthorised personnel cannot access it
- Printed data should be shredded when it is no longer needed
- Data stored on a computer should be protected by strong passwords that are changed regularly. We encourage all staff to use a password manager to create and store their passwords.
- Data stored on CDs or memory sticks must be locked away securely when they are not being used
- The DPO must approve any cloud used to store data
- Servers containing personal data must be kept in a secure location, away from general office space
- Data should be regularly backed up in line with the company’s backup procedures
- Data should never be saved directly to mobile devices such as laptops, tablets or smartphones
- All servers containing sensitive data must be approved and protected by security software and strong firewall.