Clarity Cleans needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people the organization 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 that Clarity Cleans:
- 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
- Protect itself from the risks of a data breach.
Data Protection Law
The Data Protection Act 1998 describes how organisations – including Clarity Cleans – 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 disclosed unlawfully.
The Data Protection Act is underpinned by eight important principles. These say that personal 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 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 Economic Area (EEA), unless that country or territory also ensure an adequate level of protection.
PEOPLE, RISKS AND RESPONSIBILITIES
This policy applies to:
- The Head Office of Clarity Cleans
- All branches of Clarity Cleans
- All sites in which Clarity Cleans are located
- All staff and volunteers of Clarity Cleans
- All contractors, suppliers and other people working on behalf of Clarity Cleans
It apples 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
- …plus any other information relating to individuals
Data protection risks
This policy helps to protect Clarity Cleans from some very real data security risks, including: –
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, al individuals should be free to choose how the company uses date 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 Clarity Cleans 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 has ultimate responsibility for ensuring that Clarity Cleans meets its legal obligations.
The HR Manager (Sally Ford) 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 Clarity Cleans holds on them
The Office Manager (Chelsey Bradshaw) 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 in functioning properly
- Evaluating third-party services the company is considering using to store or process data.
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 their line managers.
- Clarity Cleans will provide training to all employees to help them underlay their responsibilities when handling data.
- Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
- In particular, strong passwords must be used and they should never be shared
- Personal data should not be disclosed to unauthorized people, either within the company or externally.
- Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
- Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the HR Manager.
When data is stored on paper, it should be kept in a secure place where unauthorized people cannot see it.
These guidelines also apply to data that us 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 unauthorized 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 unauthorized access, accidental deletion and malicious hacking attempts:
- Data should be protected by strong passwords that are changed regularly and never shared between employees.
- Data should only be stored on designated drives and servers and these should be sited in a secure location.
- Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Clarity Cleans 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:
- Computer screens should be locked when workstations are left unattended.
- Personal data should not be shared informally. In particular by email.
- Personal data should not be transferred outside of EEA.
The law requires Clarity Cleans to take reasonable steps to ensure data is kept accurate and up to date.
- 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.
- Clarity Cleans will make sure its easy for data subjects to update the information held for them.
SUBJECT ACCESS REQUESTS
All individuals who are the subject of personal data held by Clarity Cleans 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 and addressed to the HR Manager. The HR Manager can supply a standard request form, although individuals do not have to use it.
Individuals will be charged £10 per subject access request. The HR Manager will aim to provide the relevant information within 14 days.
The HR Manager 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 law enforcement agencies without the consent of the data subject.
Under these circumstances, Clarity Cleans will disclose requested data. However, the HR Manager will ensure the request is legitimate, seeking assistance from the Managing Director and from the company’s legal advisers where necessary.
Clarity Cleans 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. This is available on request.