Privacy and Data Protection Policy
The purposes for which personal data may be used by us:
Personnel, administrative, financial, regulatory and business development purposes.
Business purposes include the following:
- Compliance with our legal, regulatory and corporate governance obligations and good practice
- Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
- Ensuring business policies are adhered to (such as policies covering email and internet use)
- Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking
- Investigating complaints
- Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments
- Monitoring staff conduct, disciplinary matters
- Marketing our business
- Improving services
‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal data we gather may include: individuals' phone number, email address, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.
This policy applies to all staff, who must be familiar with this policy and comply with its terms.
This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.
Who is responsible for this policy?
for further information about this policy and how it relates to you if necessary. As our data protection officer (DPO), Sharron McMurray has overall responsibility for the day-to-day implementation of this policy. If you are contractor, teacher or a student you can contact the DPO Sharron Mc Murray via firstname.lastname@example.org
HHC shall comply with the principles of data protection (the Principles) enumerated in the EU General Data Protection Regulation. We will make every effort possible in everything we do to comply with these principles. The Principles are:
1. Lawful, fair and transparent
Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.
2. Limited for its purpose
Data can only be collected for a specific purpose.
3. Data minimisation
Any data collected must be necessary and not excessive for its purpose.
The data we hold must be accurate and kept up to date.
We cannot store data longer than necessary.
6. Integrity and confidentiality
The data we hold must be kept safe and secure.
Accountability and transparency
We must ensure accountability and transparency in all our use of personal data. We must show how we comply with each Principle. You are responsible for keeping a written record of how all the data processing activities you are responsible for comply with each of the Principles. This must be kept up to date and must be approved by the DPO. To comply with data protection laws and the accountability and transparency Principle of GDPR, we must demonstrate compliance. You are responsible for understanding your particular responsibilities to ensure we meet the following data protection obligations:
· Fully implement all appropriate technical and organisational measures
· Maintain up to date and relevant documentation on all processing activities
· Conducting Data Protection Impact Assessments
· Implement measures to ensure privacy by design and default, including:
o Data minimisation
o Allowing individuals to monitor processing
o Creating and improving security and enhanced privacy procedures on an ongoing basis
Fair and lawful processing
We must process personal data fairly and lawfully in accordance with individuals’ rights under the first Principle. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.
If we cannot apply a lawful basis (explained below), our processing does not conform to the first principle and will be unlawful. Data subjects have the right to have any data unlawfully processed erased
Lawful basis for processing data
We must establish a lawful basis for processing data. Ensure that any data you are responsible for managing has a written lawful basis approved by the DPO. It is your responsibility to check the lawful basis for any data you are working with and ensure all of your actions comply the lawful basis. At least one of the following conditions must apply whenever we process personal data:
We hold recent, clear, explicit, and defined consent for the individual’s data to be processed for a specific purpose.
The processing is necessary to fulfil or prepare a contract for the individual.
3. Legal obligation
We have a legal obligation to process the data (excluding a contract).
4. Vital interests
Processing the data is necessary to protect a person’s life or in a medical situation.
5. Public function
Processing necessary to carry out a public function, a task of public interest or the function has a clear basis in law.
6. Legitimate interest
The processing is necessary for our legitimate interests. This condition does not apply if there is a good reason to protect the individual’s personal data which overrides the legitimate interest.
· Analysing and documenting the type of personal data we hold
· Checking procedures to ensure they cover all the rights of the individual
· Identify the lawful basis for processing data
· Ensuring consent procedures are lawful
· Implementing and reviewing procedures to detect, report and investigate personal data breaches
· Store data in safe and secure ways
· Assess the risk that could be posed to individual rights and freedoms should data be compromised
· Fully understand your data protection obligations
· If you are a student you must never disclose data of any fellow student
· Check that any data processing activities you are dealing with comply with our policy and are justified
· Do not use data in any unlawful way
· Do not store data incorrectly, be careless with it or otherwise cause us to breach data protection laws and our policies through your actions
· Comply with this policy at all times
· Raise any concerns, notify any breaches or errors, and report anything suspicious or contradictory to this policy or our legal obligations without delay
Responsibilities of the Data Protection Officer
· Keeping the team and teachers updated about data protection responsibilities, risks and issues
· Reviewing all data protection procedures and policies on a regular basis
· Arranging data protection training and advice for all staff members and those included in this policy
· Answering questions on data protection from staff, board members and other stakeholders
· Responding to individuals such as clients and employees who wish to know which data is being held on them by us
· Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing
Responsibilities of the IT Manager
· Ensure all systems, services, software and equipment meet acceptable security standards
· Checking and scanning security hardware and software regularly to ensure it is functioning properly
· Researching third-party services, such as cloud services the company is considering using to store or process data
Responsibilities of the Marketing Manager
· Approving data protection statements attached to emails and other marketing copy
· Addressing data protection queries from clients, target audiences or media outlets
· Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy
Accuracy and relevance
We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO.
We will keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third party organisations.
Storing data securely
· In cases when data is stored on printed paper, it should be kept in a secure place where unauthorised personnel cannot access it
· Printed data should be shredded when it is no longer needed
· Data stored on a computer should be protected by strong passwords that are changed regularly. We encourage all staff to use a password manager to create and store their passwords.
· Data stored on CDs or memory sticks must be encrypted or password protected and locked away securely when they are not being used
· The DPO must approve any cloud used to store data
· Servers containing personal data must be kept in a secure location, away from general office space
· Data should be regularly backed up in line with the company’s backup procedures
· Data should never be saved directly to mobile devices such as laptops, tablets or smartphones
· All servers containing sensitive data must be approved and protected by security software
· All possible technical measures must be put in place to keep data secure
We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner consistent with our data retention guidelines.
Transferring data internationally
There are restrictions on international transfers of personal data. We will not transfer personal data abroad, or anywhere else outside of normal rules and procedures without express permission from the DPO.
Individuals have rights to their data which we must respect and comply with to the best of our ability. We must ensure individuals can exercise their rights in the following ways:
1. Right to be informed
· Providing privacy notices which are concise, transparent, intelligible and easily accessible, free of charge, that are written in clear and plain language, particularly if aimed at children.
· Keeping a record of how we use personal data to demonstrate compliance with the need for accountability and transparency.
2. Right of access
· Enabling individuals to access their personal data and supplementary information
· Allowing individuals to be aware of and verify the lawfulness of the processing activities
3. Right to rectification
· We must rectify or amend the personal data of the individual if requested because it is inaccurate or incomplete.
· This must be done without delay, and no later than one month. This can be extended to two months with permission from the DPO.
4. Right to erasure
· We must delete or remove an individual’s data if requested and there is no compelling reason for its continued processing.
5. Right to restrict processing
· We must comply with any request to restrict, block, or otherwise suppress the processing of personal data.
· We are permitted to store personal data if it has been restricted, but not process it further. We must retain enough data to ensure the right to restriction is respected in the future.
6. Right to object
· We must respect the right of an individual to object to data processing based on legitimate interest or the performance of a public interest task.
· We must respect the right of an individual to object to direct marketing, including profiling.
· We must respect the right of an individual to object to processing their data for scientific and historical research and statistics.
7. Rights in relation to automated decision making and profiling
· We must respect the rights of individuals in relation to automated decision making and profiling.
· Individuals retain their right to object to such automated processing, have the rationale explained to them, and request human intervention.
Principle trading address: 10 Wiseton Road London SW17 7EF DPO Tel. 020 8772 7702 email@example.com
Addendum note about cookies and third parties
Using third party controllers and processors
We will never share your data with anyone and where we use the services of data processors (e.g. mailchimp) we will ensure they can provide sufficient guarantees under GDPR and rights of data subjects will be respected and protected.
where appropriate to gather information about your computer in order to assist us in improving
We may gather information about your general internet use by using the cookie. Where used,
these cookies are downloaded to your computer and stored on the computer’s hard drive. Such
information will not identify you personally. It is statistical data. This statistical data does not
identify any personal details whatsoever.
You can adjust the settings on your computer to decline any cookies if you wish. This can easily
be done by activating the reject cookies setting on your computer.