1. Context and overview
iDaC Solutions Ltd needs to gather and use certain information about individuals.
These can include customers, suppliers, business contracts, employees and other people the organisation has a relationship with or may need to contact. The company will only require necessary information that is relevant to the relationship.
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 iDaC Solutions:
- Complies with the General Data Protection Regulation and follows good practice.
- Protects the rights of staff, customer and partners.
- Is open about how it stores and processes individuals’ data.
- Protects itself from the risks of a data breach.
General Data Protection Regulation (GDPR)
The General Data Protection Regulation 2016 replaces the Data Protection Act 1998, it’s purpose is to protect the rights of living individuals and ensures that personal data is not processed without their knowledge and/or consent.
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 disclosed unlawfully.
2. People, risks and responsibilities
This policy applies to:
- The office of iDaC Solutions
- All staff of iDaC Solutions
- All contractors, suppliers and other people working on behalf of iDaC Solutions
It applies to all data that the company holds relating to identifiable individuals which includes:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Plus, any other information relating to individuals
Data protection risks
This policy helps to protect iDaC Solutions 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 iDaC Solutions has some responsibility for ensuring data is collected, stored and handled appropriately. Each member within the team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
The managers ultimately are responsible for ensuring that iDaC Solutions meet the legal obligations and are responsible for:
- Keeping the company updated about data protection responsibilities, risks and issues.
- Reviewing the procedures and policies to insure they are in line with this current policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data iDaC Solutions holds about them.
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
The IT suppler, Bluechip, is responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks to ensure security hardware and software is functioning properly.
- Evaluating any third-party services, the company is considering using to store or process data, such as cloud computing services.
3. 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 management.
- iDaC Solutions 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 below.
- Strong passwords must be used and should never be 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.
- Employees should request help from management if they are unsure about any aspect of data protection.
4. Data storage
These guidelines describe how and where data should be safely stored. When data is stored on paper it should be kept in a secure place where unauthorised people cannot see it, this also applies to data that is usually stored electronically.
- When not required, the paper or files should be kept in a secure drawer or filing cabinet.
- Data printouts should be shredded and disposed of when no longer required.
- Any documents containing personal data (staff information) should be kept secure and away from general office space.
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.
- Data should be stored on designated drives and servers (J:Drive).
- Data should be backed up frequently and in line with the company’s agreement with Bluechip.
- All servers and computers containing data should be protected by approved security software and a firewall.
5. Data use
- When working with personal data, employees should ensure the screens of their computers are locked when left unattended.
- Personal data should not be shared informally.
- Employees should not save copies of personal data to their own computers. They should always access and update information on the company’s systems (SAGE or CRM) excluding the use of company laptops when required e.g. meetings.
6. Data accuracy
The law requires iDaC Solutions 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 take 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 example, confirming a customer’s details when they call.
- Data should be updated as inaccuracies are discovered. For example, if a customer can no longer be reached on their stored telephone number it should be removed from the database.
- Documents containing personal data must have identifiable file names which include the date and source.
7. Subject access requests
All individuals who are the subject of data being help be iDaC Solutions are entitled to:
- Ask what information the company holds about them and why.
- Be informed on how to keep it up to date.
- Be informed on how the company is meeting its data protection obligations.
The company will provide this information to individuals contacting the company and making a request. This information can only be provided once the company verifies the identity of the individual.
iDaC Solutions aims to ensure that individuals are aware of what data is being processed.
8. Disclosing data for other reasons
In certain circumstances, the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, iDaC Solutions will disclose requested data. However, the company will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.
9. Deletion procedure
In the event of a person/s requesting to have their record deleted from the company’s database, the company must:
- Confirm the person/s identity.
- Confirm that iDaC Solutions holds their information.
- Confirm that the information has been deleted.
To insure no duplication iDaC Solutions will keep a record of deletion requests, the information the company will require would be a name and/or company name. These records will not be accessed other then to add any person/s who have requested deletion.