Data Protection Policy & Procedure

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1 Data Prtectin Plicy & Prcedure Page 1 Prcnnect Marketing Data Prtectin Plicy V1.2

2 Data prtectin plicy Cntext and verview Key details Plicy prepared by: Adam Haycck Apprved by bard / management n: 01/01/2015 Plicy became peratinal n: 01/01/2015 Next review date: 01/01/2016 Intrductin Prcnnect Marketing needs t gather and use certain infrmatin abut individuals. These can include custmers, suppliers, business cntacts, emplyees and ther peple the rganisatin has a relatinship with r may need t cntact. This plicy describes hw this persnal data must be cllected, handled and stred t meet the cmpany s data prtectin standards and t cmply with the law. Why this plicy exists This data prtectin plicy ensures Prcnnect Marketing: Cmplies with data prtectin law and fllw gd practice Prtects the rights f staff, custmers and partners Is pen abut hw it stres and prcesses individuals data Prtects itself frm the risks f a data breach Data prtectin law The Data Prtectin Act 1998 describes hw rganisatins including Prcnnect Marketing must cllect, handle and stre persnal infrmatin. These rules apply regardless f whether data is stred electrnically, n paper r n ther materials. T cmply with the law, persnal infrmatin must be cllected and used fairly, stred safely and nt disclsed unlawfully. The Data Prtectin Act is underpinned by eight imprtant principles. These say that persnal data must: Page 2 Prcnnect Marketing Data Prtectin Plicy V1.2

3 1. Be prcessed fairly and lawfully 2. Be btained nly fr specific, lawful purpses 3. Be adequate, relevant and nt excessive 4. Be accurate and kept up t date 5. Nt be held fr any lnger than necessary 6. Prcessed in accrdance with the rights f data subjects 7. Be prtected in apprpriate ways 8. Nt be transferred utside the Eurpean Ecnmic Area (EEA), unless that cuntry r territry als ensures an adequate level f prtectin Peple, risks and respnsibilities Plicy scpe This plicy applies t: The head ffice f Prcnnect Marketing All branches f Prcnnect Marketing All staff and vlunteers f Prcnnect Marketing All cntractrs, suppliers and ther peple wrking n behalf f Prcnnect Marketing It applies t all data that the cmpany hlds relating t identifiable individuals, even if that infrmatin technically falls utside f the Data Prtectin Act This can include: Names f individuals Pstal addresses addresses Telephne numbers plus any ther infrmatin relating t individuals Data prtectin risks This plicy helps t prtect Prcnnect Marketing frm sme very real data security risks, including: Breaches f cnfidentiality. Fr instance, infrmatin being given ut inapprpriately. Failing t ffer chice. Fr instance, nce, all individuals shuld be free t chse hw the cmpany uses data relating t them. Reputatinal damage. Fr instance, the cmpany culd suffer if hackers successfully gained access t sensitive data. Respnsibilities Page 3 Prcnnect Marketing Data Prtectin Plicy V1.2

4 Everyne wh wrks fr r with Prcnnect Marketing has sme respnsibility fr ensuring data is cllected, stred and handled apprpriately. Each team that handles persnal data must ensure that it is handled and prcessed in line with this plicy and data prtectin principles. Hwever, these peple have key areas f respnsibility: The bard f directrs is ultimately respnsible fr ensuring that Prcnnect Marketing meets its legal bligatins. The Data Prtectin Officer, Barry Raymnd, is respnsible fr: Keeping the bard updated abut data prtectin respnsibilities, risks and issues. Reviewing all data prtectin prcedures and related plicies, in line with an agreed schedule. Arranging data prtectin training and advice fr the peple cvered by this plicy. Handling data prtectin questins frm staff and anyne else cvered by this plicy. Dealing with requests frm individuals t see the data Prcnnect Marketing hlds abut them (als called subject access requests ). Checking and apprving any cntracts r agreements with third parties that may handle the cmpany s sensitive data. The IT manager, Adam Haycck, is respnsible fr: Ensuring all systems, services and equipment used fr string data meet acceptable security standards. Perfrming regular checks and scans t ensure security hardware and sftware is functining prperly. Evaluating any third-party services the cmpany is cnsidering using t stre r prcess data. Fr instance, clud cmputing services. The Marketing Manager, Adam Haycck, is respnsible fr: Apprving any data prtectin statements attached t cmmunicatins such as s and letters. Addressing any data prtectin queries frm jurnalists r media utlets like newspapers. Where necessary, wrking with ther staff t ensure marketing initiatives abide by data prtectin principles. General staff guidelines Page 4 Prcnnect Marketing Data Prtectin Plicy V1.2

5 The nly peple able t access data cvered by this plicy shuld be thse wh need it fr their wrk. Data shuld nt be shared infrmally.. When access t cnfidential infrmatin is required, emplyees can request it frm their line managers. Prcnnect Marketing will prvide training t all emplyees t help them understand their respnsibilities when handling data. Emplyees shuld keep all data secure, by taking sensible precautins and fllwing the guidelines belw. In particular, strng passwrds must be used and they shuld never be shared. Persnal data shuld nt be disclsed t unauthrised peple, either within the cmpany r externally. Data shuld be regularly reviewed and updated if it is fund t be ut f date. If n lnger required, it shuld be deleted and dispsed f. Emplyees shuld request help frm their line manager r the data prtectin fficer if they are unsure abut any aspect f data prtectin. Data strage These rules describe hw and where data shuld be safely stred. Questins abut string data safely can be directed t the IT manager r data cntrller. When data is stred n paper, it shuld be kept in a secure place where unauthrised peple cannt see it. These guidelines als apply t data that is usually stred electrnically but has been printed ut fr sme reasn: When nt required, the paper r files shuld be kept in a lcked drawer r filing cabinet. Emplyees shuld make sure paper and printuts are nt left where unauthrised peple culd see them, like n a printer. Data printuts and paperwrk shuld be shredded and dispsed f securely when n lnger required. When data is stred electrnically, it must be prtected frm unauthrised access, accidental deletin and malicius hacking attempts: Page 5 Prcnnect Marketing Data Prtectin Plicy V1.2

6 Data shuld be prtected by strng passwrds that are changed regularly and never shared between emplyees. If data is stred n remvable media (like a CD r DVD), these shuld be kept lcked away securely when nt being used. Data shuld nly be stred n designated drives and servers,, and shuld nly be upladed t an apprved clud cmputing services. Servers cntaining persnal data shuld be sited in a secure lcatin, away frm general ffice space. Data shuld be backed up frequently.. Thse backups shuld be tested regularly, in line with the cmpany s standard backup prcedures. Data shuld never be saved directly t laptps r ther mbile devices like tablets r smart phnes. All servers and cmputers cntaining data shuld be prtected by apprved security sftware and a firewall. Data use Persnal data is f n value t Prcnnect Marketing unless the business can make use f it. Hwever, it is when persnal data is accessed and used that it can be at the greatest risk f lss, crruptin r theft: When wrking with persnal data, emplyees shuld ensure the screens f their cmputers are always lcked when left unattended. Persnal data shuld nt be shared infrmally. In particular, it shuld never be sent by , as this frm f cmmunicatin is nt secure. Data must be encrypted befre being transferred electrnically.. The IT manager can explain hw t send data t authrised external cntacts. Persnal data shuld never be transferred utside f the Eurpean Ecnmic Area. Emplyees shuld nt save cpies f persnal data t their wn cmputers. Always access and update the central cpy f any data. Data accuracy The law requires Prcnnect Marketing t take reasnable steps t ensure data is kept accurate and up t date. Page 6 Prcnnect Marketing Data Prtectin Plicy V1.2

7 The mre imprtant it is that the persnal data is accurate, the greater the effrt Prcnnect Marketing shuld put int ensuring its accuracy. It is the respnsibility f all emplyees wh wrk with data t take reasnable steps t ensure it is kept as accurate and up t date as pssible. Data will be held in as few places as necessary.. Staff shuld nt create any unnecessary additinal data sets. Staff shuld take every pprtunity t ensure data is updated. Fr instance, by cnfirming a custmer s details when they call. Prcnnect Marketing will make it easy fr data subjects t update the infrmatin Prcnnect Marketing hlds abut them. Fr instance, via the cmpany website. Data shuld be updated as inaccuracies are discvered.. Fr instance, if a custmer can n lnger be reached n their stred telephne number, it shuld be remved frm the database. It is the marketing manager s respnsibility t ensure marketing databases are checked against industry suppressin files every 28 days. Subject access requests All individuals wh are the subject f persnal data held by Prcnnect Marketing are entitled t: Ask what infrmatin the cmpany hlds abut them and why. Ask hw t gain access t it. Be infrmed hw t keep it up t date. Be infrmed hw the cmpany is meeting its data prtectin bligatins. If an individual cntacts the cmpany requesting this infrmatin, this is called a subject access request. Subject access requests frm individuals duals shuld be made by , addressed t the data cntrller at The data cntrller can supply a standard request frm, althugh individuals d nt have t use this. Individuals will be charged 10 per subject access request. est. The data cntrller will aim t prvide the relevant data within 14 days. The data cntrller will always verify the identity f anyne making a subject access request befre handing ver any infrmatin. Page 7 Prcnnect Marketing Data Prtectin Plicy V1.2

8 Disclsing data fr ther reasns In certain circumstances, the Data Prtectin Act allws persnal data t be disclsed t law enfrcement agencies withut the cnsent f the data subject. Under these circumstances, Prcnnect Marketing will disclse requested data. Hwever, the data cntrller will l ensure the request is legitimate, seeking assistance frm the bard and frm the cmpany s legal advisers where necessary. Prviding infrmatin Prcnnect Marketing aims t ensure that individuals are aware that their data is being prcessed, and that they understand: Hw the data is being used Hw t exercise their rights T these ends, the cmpany has a privacy statement, setting ut hw data relating t individuals is used by the cmpany. Page 8 Prcnnect Marketing Data Prtectin Plicy V1.2

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