The people named below have responsibility of updating and enforcing the Data Protection Policy. If you would like to make any suggestions on how this plan can be improved or changes you would like to make to the plan, then please contact one of the following people:
Name: Adam Wilcock (email@example.com)
adamwilcock.com views security and privacy as integral to the function of the business. This commitment ensures compliance with the General Data Privacy Regulations. Keeping our staff informed and policies enforced is a crucial aspect to this commitment.
Data Protection Policy
adamwilcock.com needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people that the organisation may have a relationship with or 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 adamwilcock.com:
- Complies with the data protection law and follows good practice
- Protects the rights of staff, customers and partners
- Is open about how it stores and processes an individuals’ data
- Protects itself from the risks of a data breach
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside the Data Protection Act 1998. This can include names of individuals, postal addresses, telephone numbers, email addresses and any other information relating to an individual.
This policy applies to:
- All offices of adamwilcock.com
- All staff, consultants and work experience/placement students at adamwilcock.com
- All contractors, suppliers and other individuals working on behalf of adamwilcock.com
Data Protection Law
The Data Protection Act 1998 describes how organisations – including adamwilcock.com – must collect, handle and store personal information. These rules apply regardless of whether the data is stored electronically, on paper, or in any other format. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The Data Protection Act 1998 is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully.
- Be obtained only for specific, lawful purposes.
- Be adequate, relevant and not excessive.
- Be accurate and kept up to date.
- Not be held for any longer than necessary.
- Be processed in accordance with the rights of data subjects.
- Be protected in appropriate ways.
- Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.
Data Protection Risks
This policy helps to protect adamwilcock.com from some very real data security risks, including:
- Breaches of confidentiality – For instance, information being given out or passed on to others inappropriately.
- Failing to offer choice – For instance, all individuals should be free to choose how the company uses. Data relating to them.
- Reputational damage – For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with adamwilcock.com has some responsibility for ensuring data is collected, handled and stored appropriately. Everyone that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
However, adamwilcock.com (including all staff and partners) is ultimately responsible for ensuring that the firm meets its’ legal obligations.
- Keeping up to date about data protection responsibilities, risks and issues
- Reviewing all data protection procedures and related policies, in line with the agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and any other individuals covered by this policy.
- Dealing with requests from individuals to the date that adamwilcock.com holds about them (also called ”subject access requests”)
- Checking and approving and 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 that the company is considering using to store or process data e.g. cloud computing services.
- Approving any data protection statements attached to communications such as emails and letters.
- Addressing any data protection queries from journalists or media outlets.
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
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.
- adamwilcock.com 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 set out in this policy.
- Strong passwords must be used, and they should never be shared.
- Personal data should not be disclosed to unauthorised individuals, 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, data should be deleted and destroyed from all devices.
- Employees should request help from ·their manager if they are unsure about any aspect of data protection.
This section discusses how and where data should be safely stored. Questions about storing data safely should be directed to Adam Wilcock. adamwilcock.com cannot be a paperless company. However, 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.
- When not required, files should be kept in a locked drawer or filing cabinet.
- Employee should make sure that papers and printouts are not left where unauthorised people can see them e.g. on a printer.
- Data printouts should be shredded and disposed of securely when no longer required.
When data is stored electronically it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data should always be protected by strong passwords that are changed regularly and not shared unnecessarily between employees.
- If data is stored on a removable device e.g. USB or External Hard Drive, 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 an approved cloud computing service.
- 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.
- Data should never be saved locally to laptops desktops or other mobile devices.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to adamwilcock.com unless the business can make use of it. However, when personal data is accessed and used it becomes at 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, and particularly never sent via email.
- Data must be encrypted before being transferred electronically. adamwilcock.com can explain how to send data to authorised external contacts.
- Personal data should never be transferred outside of the European Economic Area (EEA).
- Employees should not save. copies of personal data onto their own computers. Always access and update the central copy of any data.
The law requires adamwilcock.com to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the data is accurate, the greater the effort the company 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 up to date as possible.
- Data will be held in as few places as necessary. Staff should not create any unnecessary data sets.
- Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
- adamwilcock.com aims to make it easy for data subjects to update the information that the company holds about them. For instance, via a customer service phone call or 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
Subject Access Requests
All individuals who are the subject of personal data held by adamwilcock.com 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 its data protection obligations.
If an individual contact the company requesting this information, this is called a Subject Access Request.
Subject Access Requests from individuals should be made by email, addressed to Adam Wilcock on firstname.lastname@example.org
Individuals will be charged at £10.00 per Request. adamwilcock.com will aim to provide the relevant data within 14 days.
The member of staff handling the enquiry will ALWAYS verify the identity of anyone making a Subject Access Request before handing over any information.
In certain circumstances, the Data Protection Act 1998 allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, adamwilcock.com will disclose the requested data. However, staff will ensure that the request is legitimate, asking for identification, and seeking assistance from the manager and the company’s legal advisers where necessary.
adamwilcock.com aims to ensure that all individuals are aware that their data is being processed, and that they understand:
- How the data is being used
- How to exercise their rights
Adam Wilcock is responsible for maintaining and implementing the Data Protection policy on behalf of adamwilcock.com who will carry out an annual review of the policy to verify it is in effective operation.
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