Roy Braidwood and Sons 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.
This policy applies to:
- The head office of Roy Braidwood and Sons Transport Ltd,
- All staff and volunteers of Roy Braidwood and Sons Transport Ltd and,
- All contractors, suppliers and other people working on behalf of Roy Braidwood and Sons Transport Ltd.
The Data Protection Act 1998 describes how organisations – including Roy Braidwood and Sons Transport Ltd – must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials.
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,
- Postal addresses,
- Email addresses,
- Telephone numbers,
- And any other information relating to individuals.
This policy helps protect Roy Braidwood and Sons Transport Ltd from some very real data security risks, 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 successfully gained access to sensitive data.
Everyone who works for or with Roy Braidwood and Sons Transport 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 in line with this policy and data protection principles.
However, these people have key areas of responsibility:
- The Managing Director is ultimately responsible for ensuring that Roy Braidwood and Sons Transport Ltd meets its legal obligations.
- Roy Braidwood and Sons Transport Ltd has appointed Catherine Hunt as the data protection officer, who is responsible for:
- Keeping the board updated about data protections 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 tsee the data Roy Braidwood and Sons Transport Ltd holds about them (know as ‘Subject access requests’)
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
- The IT manager, Matthew Braidwood 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 kept up to date and is functioning properly.
- Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
General staff guidelines can be found on the privacy notice which can be found on display on the staff noticeboard.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to a member of management. When the 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, like 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 be protected by strong passwords that are changed regularly and never shared between employees.
- If data is stored on removable media [DVD, USB drive etc.] 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 services.
- 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 directly to laptops or other mobile devices like tablets or smartphones.
- All servers and computers containing data should be protected by an approved security software and a firewall.
Personal data is of no value to Roy Braidwood and Sons Transport 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 personal data, employees should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally, it should never be sent by email, as this form of communication is not secure.
- Data must be encrypted before being transferred electronically. A member of management can explain how to send data to authorised external contacts.
- Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires Roy Braidwood and Sons Transport Ltd to take reasonable steps to ensure data is kept accurate and up to date. It is the responsibility of all employees who work with data to reasonable steps to ensure it is kept as accurate and up to date as possible.
- Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
- Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
- Roy Braidwood and Son Transport Ltd will male it easy for data subjects to update the information we hold about them.
- Data should be updated as inaccuracies are discovered. For example, if a customers 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 Roy Braidwood and Sons Transport Ltd 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 contacts the company requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email, addressed to the data protection officer at email@example.com.
The data protection officer can supply a standard request form, although individuals do not have to use this.
Individuals will be charged £10 per subject access request. The data protection officer will aim to provide the relevant data within 14 days. The data protection officer will always verify the identity of anyone making a subject access request before handing over any information.
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without consent of the data subject. Under these circumstances, Roy Braidwood and Sons Transport Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from upper management and from the company’s legal advisers where necessary.
Roy Braidwood and Sons Transport 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.
– The Directors.