CREWKERNE CARRIERS LTD – General protection policy - 2018

Key details

·      Policy Prepared by: Terry Pitcher

·      Approved by Directors / Management:

·      Policy became operational on: 29 April 2018

·      Next review date: 29 April 2018 or as needed

Introduction

Crewkerne Carriers LTD needs to gather and use certain information about individuals.

This can include customers, suppliers, business contacts, employees and other people the company 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 Crewkerne Carriers 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 individual’s data

·      Protects itself from the risk of data breach

Data protection law

 The General Data Protection Regulation (GDPR) describes how organisations – including Crewkerne Carriers LTD -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 used unlawfully.

The General Data Protection Regulation (GDPR) is underpinned by eight important principles. These say that 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 to be held for any longer than necessary

·      Processed in accordance with the rights of data subjects

·      Be protected in appropriate ways

·      Not be transferred outside the European area (EEA), unless that country or territory also ensures an adequate protection

 

People risks responsibilities

Policy scope

 This policy applies to:

·      All directors /management of Crewkerne Carriers LTD

·      All staff of Crewkerne Carriers LTD

·      All contactors and other people working on behalf of Crewkerne Carriers LTD

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the General Data Protection Regulation (GDPR). This can include:

·      Names of individuals

·      Postal addresses

·      Email Addresses

·      Telephone numbers

·      …plus, any other information relating to individuals

Data protection risk

 This policy helps protect Crewkerne Carriers LTD from some very real data security risk, including:

·      Breaches of confidentiality. For instance, information being given out 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 gained access to sensitive data.

Responsibilities

 Everyone who works for or with Crewkerne Carriers LTD has some responsibility for ensuring data is collected and handled appropriately.

However, these people have key areas of responsibility;

·      The directors/ management is ultimately responsible for ensuring that Crewkerne Carriers LTD meets its legal obligations.

The directors/ management is responsible for:

·      Keeping staff updated about data protection responsibilities risk and issues.

·      Reviewing all data protection procedures and related policies.

·      Handling data protection questions from staff.

·      Dealing with request from individuals to see the data Crewkerne Carriers LTD holds about them(also called ‘subject access request’)

·      Checking and approving any contracts or agreements with third parties that may hold sensitive data. 

·      Approving any data protection statements attached to communications such as letters and emails.

·      Addressing any data protection queries from journalist and media outlets like newspapers.

The IT Manager Terry Pitcher is responsible for:

·      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 process data, For instance, cloud computing services.

 General staff guidelines

·      The only people to access data covered by this policy should be those who need to work on it.

·      Employees should keep all data secure, by taking sensible precautions and following the guide lines below.

·      In particular, strong passwords must be used and never shared.

·      Personal data should not be disclosed to unauthorised people.

·      Data should be regularly reviewed and updated if it is found to be out of date. If it is no longer required, it should be deleted and disposed of.

·      Employees should request help if they are unsure about any aspect of data protection.

Data Storage

These rules describe how and where data should be stored.

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, this includes delivery and collection notes.

·      Data printouts should be shredded and disposed of securely when no longer needed.  

When data is stored electronically, it must be protected from unauthorised access, accidental and malicious hacking attempts.

·      Data should be protected by strong passwords that are changed regularly.

·      If data is stored on removable media these should be kept locked away securely when not being used.

·      Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s backup procedures. 

·      All computers containing data should be protected by approved security and a fire wall.

 Data use

Personal data is of no value to Crewkerne Carriers LTD unless the business 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 and 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.

·      Employees should never save copies of personal data on their own computers unless accessed via the company cloud which should be password protected.

·      Mobile phones or tablets that have access to Crewkerne Carriers LTD email or iCloud must be password protected.

Data accuracy

The law requires Crewkerne Carriers LTD to take reasonable steps to ensure data is kept up to date.

The more important it is the personal data is accurate, the greater the effort Crewkerne Carriers 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 as accurate up to date as possible.

·      Data should be held in a few places as necessary

·      Staff should take every opportunity to ensure data is correct and updated. For instance, confirming customers details when they call.

·      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 data base.

Subject access request

All individuals who are subject of personal information data held by Crewkerne Carriers LTD are entitled to:

·      Ask what information the company holds.

·      Be informed how it is kept ask how to gain access to it.

·      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 request.

Subject request from Individuals should be sent via email, addressed to the directors of Crewkerne Carriers LTD.

The management 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, the data protection act allows personal data to be disclosed to a law enforcement agency without consent of the data subject.

Under these circumstances, Crewkerne Carriers LTD will disclose the requested data. However, Crewkerne Carriers LTD may check to ensure the request is legitimate, seeking advice from the company legal advisers where necessary.

Providing information

Crewkerne Carriers 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 individuals is used by the company.