TWOGs™ Ltd needs to gather and use certain information about individuals.
These can include 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 company‘s data protection standards and to comply with the law.
Why this policy exists
This data protection policy ensures TWOGs™ Ltd:
Complies with data protection law and follow good practice
Protects the rights of staff, customers and partners
Is open about how it stores and processes individuals‘ data
Protects itself from the risks of a data breach
Data protection law
The Data Protection Act 1998 describes how organisations including TWOGs™ Ltd. Must collect, handle and store personal information.
The 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.
The Data Protection Act is underpinned by eight important principles. These say that personal data must:
1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not held for any longer than necessary
6. Processed in accordance with the rights of the data subjects
7. Be protected in appropriate ways
8. Not be transferred outside of European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, risks and responsibilities
This policy applies to:
The head office of TWOGs™ Ltd.
All branches of TWOGs™ Ltd
All staff and volunteers of TWOGs™ Ltd
All contractors, suppliers and other people working on behalf of TWOGs™ Ltd
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
Names of individuals
Plus, any information relating to individuals
Data protection risks
This policy helps to protect TWOGs™ Ltd from some very real data security risks, including:
Breaches of confidentiality. For instance, information given out inappropriately
Failing to offer choice. For instance, all individuals should be free to choose how the company uses data related to them.
Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with TWOGs™ Ltd 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 inline 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 TWOGs™ Ltd meets its legal obligations.
The Data Protection Officer, Alison Ball 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 TWOGs™ Ltd 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.
The IT Manager, Andrew Raynor is responsible for:
Ensuring that 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 Marketing Manager, Andrew Callard is responsible for:
Approving any data protection statements attached to communications such as emails and letters.
Addressing any data protection queries from journalists or media outlets like newspapers.
Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
These rules describe how and where data should be safely sored. Questions about storing data safely can be directed to the IT Manager.
When data is stored on paper, it will be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is stored electronically but has been printed out for some reason:
When not required, the paper or files will be kept in a locked drawer or filing cabinet.
Employees will make sure paper and printouts are not left where unauthorised people could see them, like on a printer
Data printouts will 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 be protected by strong passwords that are changed regularly.
If data is stored removable media, these will be kept locked away securely when not being used.
Data should only be stored on designated drives and servers, and should only only be uploaded to an approved cloud computing service.
Servers containing personal data will be sited in a secure location.
Data will be backed up frequently. The backups should be tested regularly in line with TWOGs™ Ltd standard backup procedures.
Data will never be save directly to laptops or other mobile devices like tablets or smart phones.
All servers and computers containing data will be protected by approved security software and a firewall.
Personal data is of no value to TWOGs™ Ltd 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 the personal data, employees should insure 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 email, as this formal communication is not secure.
Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
Personal data should never be transferred outside of the European economic area.
Employees should not send copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires TWOGs™ Ltd to take reasonable steps to ensure data is kept accurate and up-to-date. The more important it is that the personnel data is accurate, the greater the effort TWOGs™ Ltd 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 kept as possible.
Data will be held in as few places as necessary. Staff should not create any unnecessary additional datasets.
Staff should take every opportunity to ensure data is updated. For instance by confirming a customer‘s details when they call.
TWOGs™ Ltd will make it easy for data subjects to update the information TWOGs™ Ltd hold about them. For instance via the company website.
Data should be updated as it accuracies are discovered. For instance, if a customer can a longer be reached on the storage telephone number, it should be removed from the database.
It is the marketing manager‘s responsibility to ensure marketing databases are checked against in industry suppression files every six months.
Subject access requests
All individuals who are the subject of personal data held by TWOGs™ Ltd are entitled to:
Ask what information the company holds about them and why.
Ask out to gain access to it.
Be informed how to keep you up-to-date.
Be informed how the company is meeting its data protection obligations.
If an individual contacts the company requesting this information, this is called a subject access request.
Subject access request from individuals should be made by email, addressed to the data controller at TWOGs™ Ltd . The data controller can supply standard request form, although individuals do not have to use this.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
Disclosing data for other reasons
In certain circumstances, data protection act allows personal data to be disclosed to law enforcement agencies without consent consent of the data subject.
Under these circumstances TWOGs™ Ltd Will disclose requested data stop however, the data controller will ensure the request is legitimate, seeking assistance from the board and from the companies legal advisers where necessary.
TWOGs™ Ltd 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 the individuals is used by the company.
(This is available on request. A version of the statement is also available on the companies website.)