Purpose

Pittards PLC needs to gather and use certain information about individuals as part of normal business operations. This includes information relating to 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 guidelines set out in the General Data Protection Regulation effective from 25 May 2018 – and to comply with other existing legislation.

The Data Protection Policy ensures Pittards PLC:

 

Scope

This policy applies to:

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of GDPR, this can include:

 

Data Protection Law

GDPR (General Data Protection Regulation) describes how organisations – including Pittards PLC – 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.

GDPR Article 5: Principles relating to the processing of personal data. States that personal data shall be:

 

Data Protection Risks

This policy helps to protect Pittards PLC from some very real data security risks, including:

 

Responsibilities

Everyone who works for or with Pittards PLC 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:

 

 

 

 

General Staff Guidelines

 

Data Storage

These rules describe how and where data should be stored. Questions about storing data safely can be directed to the DPO.

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, data must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

 

Data Use

Personal data is of no value to Pittards PLC unless the business 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:

 

Data Accuracy

The law requires Pittards PLC to take responsible 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 Pittards PLC 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.

 

Subject access requests

All individuals who are the subject of personal data held by Pittards PLC are entitled to:

If individuals contact the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by e-mail addressed to the DPO at dataprotection@pittards.com. The DPO can supply a standard request form, although individuals do not have to use this.

Individuals will not be charged for the access request by may be charged for manhours incurred in processing and completing the access request. The data controller will aim to provide the relevant data within 30 days. If the request requires extra time the DPO will inform the individual of the extra time required which will not exceed 90 days from the initial access request.

The data controller will always verify the identity of anyone making subject access request before handing over any information. This may require proof of identification provided to the DPO in the form of: Passport, Drivers Licence, Birth Certificate, Recognised ID Card.

 

Disclosing data for other reasons

In certain circumstances, the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Pittards PLC will disclose requested data. However, the data controller will ensure that the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

 

Providing Information

Pittards PLC aims to ensure that individuals are aware that their data is being processed, and that they understand:

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

[This is available on request.]