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Data Protection Policy GDPR for 2015 Security Services Ltd
Introduction
As individuals, we want to know that personal information about ourselves is handled properly, and we and others have specific rights in this regard. In the course of its activities the company will collect, store and process personal data, and it recognises that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.
The types of personal data that the company may be required to handle include information about current, past and prospective employees, suppliers, customers, and others with whom it communicates. The personal data, which may be held on paper or on a computer or other media, is subject to certain legal safeguards specified in the Data Protection Act 2018 (the Act) and other regulations. The Act imposes restrictions on how the company may process personal data, and a breach of the Act could give rise to criminal sanctions as well as bad publicity.
If your personal or bank details change please inform the company straight away so that accurate records may be maintained.
Status of this Policy
This policy sets out the company’s rules on data protection and the eight data protection principles contained in it. These principles specify the legal conditions that must be satisfied in relation to the obtaining, handling, processing, transportation and storage of personal data.
The company’s Data Protection Compliance Manager is responsible for ensuring compliance with the Act and with this policy. The Data Protection Compliance Manager is the Managing Director. Any questions or concerns about the interpretation or operation of this policy should be taken up in the first instance with the Data Protection Compliance Manager.
This policy is not part of the contract of employment and the company may amend it at any time. However, it is a condition of employment that employees and others who obtain, handle, process, transport and store personal data will adhere to the rules of the policy. Any breach of the policy will be taken seriously and may result in disciplinary action.
Any employee who considers that the policy has not been followed in respect of personal data about themselves or others should raise the matter with their Line Manager and/or the company’s Data Protection Compliance Manager in the first instance.
Definition of Data Protection Terms
Data is recorded information whether stored electronically, on a computer, or in certain paper-based filing systems.
Data subjects for the purpose of this policy include all living individuals about whom ABC Security Services holds personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information.
Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in possession of the company).Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal). It can even include a simple e-mail address. It is important that the information has the data subject as its focus and affects the individual’s privacy in some way. Mere mention of someone’s name in a document does not constitute personal data, but personal details such as someone’s contact details or salary would still fall within the scope of the Data Protection Act 2018.
Data controllers are the people or organisations who determine the purposes for which, and the manner in which, any personal data is processed. They have a responsibility to establish practices and policies in line with the Act. This company is the data controller of all personal data used in its business.
Data Users include employees whose work involves using personal data. Data users have a duty to protect the information they handle by following the company’s data protection and security policies at all times
Data Processors include any person who processes personal data on behalf of a data controller. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on the company’s behalf.
Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
Sensitive Personal data includes information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions, including a condition requiring the express permission of the person concerned.
Data Protection Principles
Anyone processing personal data must comply with the eight enforceable principles of good practice. These provide that personal data must be:-
- Processed fairly and lawfully
- Processed for limited purposes and in an appropriate way
- Adequate, relevant and not excessive for the purpose
- Accurate
- Not kept longer than necessary for the purpose
- Processed in line with data subjects’ rights
- Secure
- Not transferred to people or organisations situated in countries without adequate protection
Fair and Lawful Processing
The Act is intended not to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject. The data subject must be told who the data controller is (in this case this company), the purpose for which the data is to be processed by this company, and the identities of anyone to whom the data may be disclosed or transferred.
For personal data to be processed lawfully, certain specific conditions have to be met. These include, among other things, requirements that the data subject has consented to the processing, or that the processing is necessary for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive personal data is being processed, additional conditions must be met. In most cases the data subject’s explicit consent to the processing of such data will be required.
Processing for Limited Purposes
Personal data may only be processed for the specific purposes notified to the data subject when the data was first collected or for any other purposes specifically permitted by the Act. This means that personal data must not be collected for one purpose and then used for another. If it becomes necessary to change the purpose for which the data is processed, the data subject must be informed of the new purpose before any processing occurs.
Adequate Relevant and Non-Excessive Processing
Personal data should only be collected to the extent that it is required for the specific purpose notified to the data subject. Any data which is not necessary for that purpose should not be collected in the first place.
Accurate Data
Personal data must be accurate and kept up to date. Information which is incorrect or misleading is not accurate and steps should therefore be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out-of-date data should be destroyed.
Timely Processing
Personal data should not be kept longer than is necessary for the purpose. This means that data should be destroyed or erased from the company’s systems when it is no longer required.
Processing In Line With Data Subject’s Rights
Data must be processed in line with data subjects’ rights. Data subjects have a right to:-
- Request access to any data held about them by a data controller
- Prevent the processing of their data for direct-marketing purposes
- Ask to have inaccurate data amended
- Prevent processing that is likely to cause damage or distress to themselves or anyone else
Data Security
The company will ensure that appropriate security measures are taken against unlawful or unauthorised processing ofpersonal data, and against the accidental loss of, or damage to, personal data. Data subjects may apply to the courts for compensation if they have suffered damage from such a loss.
The Act requires the company to put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data may only be transferred to a third-party data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.
Maintaining data security means guaranteeing the confidentiality, integrity and availability of the personal data, defined as follows:-
- Confidentiality means that only people who are authorised to use the data can access it
- Integrity means that personal data should be accurate and suitable for the purpose for which it is processed
- Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on the company’s central computer system instead of individual PCs
Security procedures include:-
- Entry controls. Any stranger seen in entry-controlled areas should be reported
- Secure lockable desks and cupboards. Desks and cupboards should be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential)
- Methods of disposal. Paper documents should be shredded. Floppy disks and CD-ROMs should be physically destroyed when they are no longer required
- Equipment. Data users should ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended
Dealing With Subject Access Requests
A formal request from a data subject for information the company holds about them must be made in writing. Employees who receive a written request should forward it to the Data Protection Compliance Manager immediately.
When receiving telephone enquiries, employees should be careful about disclosing any personal information held on the company’s systems. In particular they should:-
- Check the caller’s identity to make sure that information is only given to a person who is entitled to it
- Suggest that the caller put their request in writing where the employee is not sure about the caller’s identity and where their identity cannot be checked.
- Refer to the Data Protection Compliance Manager for assistance in difficult situations. Employees should not be bullied into disclosing personal information
The 2015 SECURITY SERVICES LTD reserves the right at any time to make deductions from your wages in respect of any overpayments made to you and/or monies that you owe the company including in respect of holiday pay, loans, advances, allowances, expenses, cost of repairing damage to company property or vehicles.
The company will not make deductions in respect of pensions benefits due to you.
Position DIRECTOR OPERATIONS Date: 11/02/2022