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:
- Complies with GDPR and follows best practice.
- Protects the rights of staff, customers and other stakeholders
- Is open about how it stores and processes individuals’ data
- Protects itself and others from the risk of a data breach
This policy applies to:
- The head office of Pittards PLC
- All branches of Pittards PLC as they all interact with the EU
- All staff and volunteers of Pittards PLC
- All Contractors, suppliers and other people working on behalf of Pittards PLC
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:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Any other information relating to individuals
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:
- Processed fairly and lawfully.
- Collected for specified, explicit and legitimate purposes.
- Adequate, relevant and limited to what is necessary.
- Accurate and, where necessary, kept up to date.
- Kept for no longer than is necessary.
- Processed in a manner that ensures appropriate security.
Data Protection Risks
This policy helps to protect Pittards PLC from some very real data security risks, including:
- Breaches of confidentiality – For instance, information being given out inappropriately.
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
- Loss of intellectual property or other commercially sensitive information.
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:
- The Board of Directors is ultimately responsible for ensuring that Pittards PLC meets its legal obligations.
- The Data Protection Officer (DPO), is responsible for:
- Keeping the board updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data Pittards PLC holds about them (also called ‘subject access requests’).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software is functioning properly.
- Evaluating any third-party services, the company is considering using to store or process data. For instance, cloud computing services.
- The HR Director is responsible for:
- Approving any data protection statements attached to communication such as e-mails and letters.
- Addressing any new data protection queries from journalists or media outlets like newspapers.
- Where necessary, working with other staff to ensure all departments abide by data protection principles.
- The Marketing Director
- It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
General Staff Guidelines
- 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.
- Pittards PLC will provide training to all employees to help them understand their responsibilities when handling data.
- Employees should keep data secure, by taking sensible precautions and following the guidelines below.
- In particular, strong passwords must be used and they should never be shared or written down.
- Personal data should not be disclosed to any 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 DPO if they are unsure about any aspect of data protection.
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 not required, the paper or files should be kept in a locked drawer or filing cabinet.
- Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
- Data printouts should be shredded and disposed of securely when no longer
When data is stored electronically, data must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data should be protected by strong passwords that are changed regularly and never shared between employees.
- If data is stored on removable media (like a CD/DVD or Memory stick), these should be kept locked away securely when not being used.
- Data should only be stored on designated drives and servers and should only be uploaded to approved cloud computing services.
- Servers containing personal data should be sited in a secure location, away from general office space.
- Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures [please see backup procedures documentation].
- Data should never be saved to laptops or other mobile devices like tablets or smart phones.
- All servers and computers containing data should be protected by approved security software and a firewall.
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:
- When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally. In particular, it should never be sent by e-mail, as this form of communication is not secure.
- Data must be encrypted before being transferred electronically. The IT team can explain how to send data to authorised external contacts.
- Personal Data should never be transferred outside the European Economic Area.
- Employees should not save copies of personal data to their own computers. Always access and update central copies of any data.
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.
- 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.
- Pittards PLC will make it easy for data subjects to update the information Pittards PLC holds about them. For instance, via the company website.
- Data should be updated as soon as inaccuracies are discovered. For Instance, if a customer can no longer be reached on their stored telephone number, it should be removed from our records.
Subject access requests
All individuals who are the subject of personal data held by Pittards PLC are entitled to:
- Ask what information the company holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how the company is meeting is GDPR obligations.
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 firstname.lastname@example.org. 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.
Pittards PLC aims to ensure that individuals are aware that their data is being processed, and that they understand:
- How the data is being used
- How to exercise their rights
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.
- Policy Prepared by: Andrew Jackson
- Approved by HR on: 18/05/18
- Policy Became Operational on: 25/05/18
- Next Review Date :18/05/19