DATA PROTECTION POLICY
Section A: Overview
1. The reason for this policy
- You have legal rights with regard to the way your personal data is handled.
- In the course of our business activities we collect, store and process personal data about our customers, suppliers and other third parties and therefore, in order to comply with the law and to maintain confidence in our business, we acknowledge the importance of correct and lawful treatment of this data.
- All people working in or with our business are obliged to comply with this policy when processing personal data.
- This policy and any other documents referred to in it sets out the basis on which we will process any personal data we collect from data subjects, for example, customers and business contacts, or that is provided to us by data subjects or other sources.
- In this policy when we say “you’ or “your” we are generally referring to the data subjects unless the context requires otherwise.
- It also sets out our obligations in relation to data protection under the General Data Protection Regulation 2016 (“the GDPR Rules”).
- This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer and store personal data.
- We agree to ensure that all of our directors, employees, consultants and agents comply with this policy.
- We aim to ensure the correct, lawful, and fair handling of your personal data and to respect your legal rights.
3. The meaning of key Data Protection terms
- data is information which is 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 we hold 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 our possession). Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and behaviour.
- data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They are responsible for establishing practices and policies in line with the Act. We are the data controller of all personal data used in our business for our own commercial purposes.
- processing is any activity that involves use of personal 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.
4. Summary of the Data Protection Principles
This Policy aims to ensure compliance with the GDPR Rules. The GDPR Rules sets out the following principles with which any party handling personal data must comply. All personal data must be:
- Processed fairly and lawfully – it must be processed fairly and lawfully and it must be processed – in relation to you as the data subject – in a transparent manner
- Processed for limited purposes and in an appropriate way – the purposes for which it is collected must be explicit, specified and legitimate
- Adequate, relevant and not excessive for the purpose
- Accurate – as well as being accurate it must be kept up to date with inaccurate data deleted
- Not kept longer than necessary for the purpose
- Processed in line with data subject’s rights
- Security – there must appropriate technical or organisational measures to ensure appropriate security
In addition, pessonal data must not be transferred outside the European Economic Area (the “EEA”) without adequate protection.
Section B: Data Protection Principles
5. Notifying Data Subjects
As part of complying with the principles in para 4 above, if you provide us with personal data we will always try to tell you:
- the purpose or purposes for which we intend to process that personal data
- the types of third parties, if any, with which we will share or to which we will disclose that personal data
- how you can limit our use and disclosure of their personal data
- if we receive personal data from other sources.
6. Lawful, Fair, and Transparent Data Processing
The GDPR Rules are not intended to prevent the processing of personal data but to ensure that it is done fairly and without adversely affecting your rights. The processing of personal data is lawful if one (or more) of the following applies:
- (consent) the data subject has consented for a specific purpose;
- (contract) if the data subject requests the processing with a view to entering into a contract or the processing is necessary for the performance of a contract
- (legal obligation) if the processing is necessary for the compliance with a legal obligation to which the data controller is subject
- (protection) processing is necessary to protect your vital interests or those of another natural person
- (public interest) it is in the public interest for a task to be carried out which requires such processing, or the task is to be carried out as a result of the exercise of any official authority held by the data controller;
- (legitimate interests) for the legitimate interest of the data controller or the party to whom the personal data is disclosed. Legitimate interest may include sharing events, insights and resources with business people who we deem to have a legitimate interest in receiving this information.
7. Processed for limited purposes and in an appropriate way
- In the course of our business, we may collect and process the personal data set out above. This may include personal data we receive directly from you (for example, by completing forms or by corresponding with us by mail, phone, email or otherwise) and data we receive from other sources (including, for example, business partners, sub-contractors in technical, payment and delivery services, credit reference agencies and others).
- We will only process personal data for the specific purposes set out above or for any other purposes specifically permitted by the GDPR Rules. We will notify those purposes to you when we first collect the personal data or as soon as possible thereafter.
8. Adequate, Relevant and not excessive for the purpose
We will only collect and process personal data for the specific purpose(s) set out above
9. Accuracy of Data and Keeping Data Up To Date
We will keep your personal data accurate and up-to-date. We will check its accuracy regularly. When we find inaccurate or out-of-date data we will take reasonable steps to amend or erase that data.
10. Timely Processing
We will only keep your personal data for a period of time which we judge is relevant and necessary taking into account the purpose(s) of collecting the personal data which are specified above.
11. Processing that is secure
In addition to the measures above:
- we will make sure that the personal data we collect is securely kept and we stop unauthorised processing and prevent its loss, destruction or damage
- we will ensure that only people who are authorised to use personal data can access it and that we have entry controls to our premises and systems, lockable desks and cupboards for confidential personal data and destruction of hard copy documents and digital storage devices
- all authorised persons must 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.
Section C: Data Subject Rights
12. You, as a data subject, have the right to information about:
- Who we are
- The purpose(s) of collecting your personal data and the legal basis for collecting it and what our legitimate interest is for processing your personal data
- The categories of personal data collected and where is to be transferred, especially if outside the EEA
- The length of time we hold personal data (or, where there is no predetermined period, details of how that length of time will be determined)
- Your rights as a data subject including your right to withdraw your consent to processing, the right to complain to the Information Commissioner and also things such as details of any legal requirement for processing personal data that may exist and any automated decision-making that we carry out.
We will try to provide this information when we collect the personal data or, if we collect the personal data from another party, when we communicate with you after the personal data is received.
13. Data Subject Access
- You may request access to any data held about you by us (a subject access request (“SAR”)
- We reserve the right to charge reasonable fees for onerous or repetitive requests.
- Data subjects must make a formal request for information we hold about them. This must be made in writing.
- When receiving telephone enquiries, we will only disclose personal data we hold on our systems if the following conditions are met:
- we will check the caller’s identity to make sure that information is only given to a person who is entitled to it.
- we will suggest that the caller put their request in writing if we are not sure about the caller’s identity and where their identity cannot be checked.
14. Accuracy of personal data: right to rectification
- We will do our best to ensure that all personal data held about you is accurate and complete. We ask that you notify us of any changes to information held about you.
- You have the right to request that any incomplete or inaccurate information held about you is rectified and to lodge a complaint with us and the Information Commissioner’s Office.
- We will respond to requests to rectify within one month.
15. Right to be forgotten
You have the right to request the deletion or removal of personal data however requests for erasure can be rejected in certain circumstances.
16. Right to restriction of Processing
You can block the processing of your personal data. This means we may be able to store it, but cannot process it further without consent. Restricting data is required where the accuracy of data is challenged – but only until the accuracy has been verified.
17. Right to data portability
- If you have provided personal data to us you have the right to transfer it from us to someone else.
- If you request it, we may be required to transmit the data directly to another organisation if feasible. We must respond without undue delay and within one month, or two months if the request is complex.
18. The right to object
You have a right to object to the processing of your data. We must stop processingunless we can demonstrate a legal ground for the processing.
19. Automated decision-making
- You have the right not to be subject to a decision based on automated processing and it produces a legal effect or other significant effect on you.
- You can request human intervention where personal data is processed using automated decision-making and can ask for an explanation of the decision to use automated decision-making.
If we use your personal data for profiling purposes:
- We will give you information fully explaining the profiling which will be carried out including its importance and the likely results of that profilinges;
- We will make sure that appropriate mathematical or statistical procedures will be used;
- We will implement technical and organisational measures which are required to minimise the risk of mistakes and to enable such mistakes to be easily corrected; and
- We will make sure that all personal data processed by us for profiling purposes will be kept secure so as to avoid discriminatory effects resulting from such profiling.
This Policy has been approved and authorised by:
|Due for Review by:
Data Protection Officer
Our data protection officer is Joe Nagle.
Commencement of this policy
This Policy shall be deemed effective as of 24.5.18 however it will not have effect retrospectively and will apply only to matters occurring after this date.
Our specific data protection measures
In relation to our use of personal data we take the following measures:
|Erasure, destruction and or deletion
|Deletion from online systems as per online system methods. Destruction of hardcopies using a shredder.
|Transmission via email
|We use Office 365, a Microsoft product which is fully password protected. In addition, we use Active Campaign, a secure CRM system.
|Transmission of hard copies
|Via postage if required.
|Storage of emails and email content
|In secured systems including email clients, CRM and project management software.
|Access of employees
|Employees have access to non-sensitive data for the purpose of delivering work, marketing and communication.
|Access of third parties
|Storage of hardcopies
|In a secured office for only as long as required.
Guidance given to all employees on the risks of hardcopy storage and safe disposal of data.
|Storage of electronic copies
|In password protected systems
|Viewing on systems
|All systems password protected.
|Viewing on devices
|All devices password protected.
|Good passwords on all devices, apps and services which use data.
Guidance to all employees on creating effective passwords
Our use of personal data and our purpose
We may collect, hold and/or process the following personal data:
|Name, job title, organisation and contact details
|For delivery of projects
For communication about events
For communication about insights
|Emails and correspondence, including attendance at events
|For tracking progress of project and client relationships