Terms of Business
DATA PROTECTION POLICY
Context and overview – Key details
Policy prepared by Chris Roper, proprietor
Policy operational as of 10th May 2018
Next review date 1st May 2020
Peak2 Valley (P2V) may need to gather and use certain information about individuals.
These may include customers, suppliers, business contacts, partners, 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.
Why this policy exists
- To ensure P2V complies with data protection law and follows good practice
- To protect rights of staff, customers and partners
- To ensure P2V is open about how it stores and processes individual’s data
- To protect against the risks of a data breach
Data protection law
The Data Protection Act 1998 describes how organisations and companies must collect, handle and store personal information.
These rules apply to storage by electronic, paper or other means.
To comply with law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The Data Protection Act is based on eight principles. Data must:
- Be processed fairly and lawfully
- Be obtained for specific, lawful purposes only
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside of the European Economic Area (EEA) unless that country or territory also ensures an adequate level of protection
People, risks and responsibilities
This policy applies to:
- The office of P2V and any branches that may be established in the future
- All staff, partners and volunteers of P2V
- All contractors, suppliers and other people working on behalf of P2V
It applies to all data the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This may include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Any other individual’s information
Data protection risks
This policy helps to protect P2V from real data security risks, including:
- Breaches of confidentiality such as information being given out inappropriately
- Failing to offer choice, so that all individuals are free to choose how the company uses data referring to them
- Reputational damage for example the company may suffer from hackers successfully gaining access to sensitive data
Everyone who works for or with P2V has some responsibility for ensuring data is collected, stored and handled appropriately.
The proprietor, Chris Roper, is responsible for all aspects of data protection implementation, compliance and review. The proprietor will ensure:
- The only people with access to data will be those who need it for their work
- Data will not be shared informally
- P2V will ensure employees, partners and co-workers are familiar with data protection requirements
- Strong passwords will be used and never shared
- Personal data should not be shared within the company or externally
- Data should be reviewed periodically and updated as necessary. If no longer required, it should be deleted and disposed of
- P2V employees, partners and co-workers should request help from Chris Roper if they are unsure of any aspects of data protection
When data is stored on paper it should be kept in a secure place where unauthorised people have no access. This includes electronically stored data that has been printed out:
- When not required, papers or files should be kept in a locked drawer or cabinet
- Paper and printouts should not be left where unauthorised people could see them
- Data printouts should be shredded and disposed of securely when no longer needed
Electronically stored data must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Strong passwords should be used that are changed regularly and not shared
- Data stored on removeable media (CD,DVD,USB) should be kept locked away securely when not being used
- Data should be stored on designated drivers and servers and only uploaded to an approved cloud computing service
- Personal data should be separately stored
- Data should be backed up frequently
- Data should not be saved directly to mobile devices such as PCs or tablets
- All servers and computers containing data must be protected by security software and a firewall
Personal data is only of value to P2V when it is of use to the company, however when personal data is accessed and used that it may be at the greatest risk of loss, corruption or theft:
- When working with personal data, computers must not be left unattended
- Personal data should not be shared informally, in particular by email, as this form of communication is not secure
- Data must be encrypted before being sent electronically
- Personal data must never be transferred outside of the EEA
- Individuals must not store personal data to their own computers
The law requires P2V to take reasonable steps to ensure data is kept accurately and up to date
- Data should be held in as few places as necessary with no additional data sets
- Data must be updated at every available opportunity, for instance when a customer calls
- P2V should remind customers to update their data at relevant opportunities, such as telephone calls or meetings
- Data should be updated as inaccuracies are discovered, for example redundant phone numbers
- Any marketing must take note of information in the industry suppression files at least every six months
Subject access request
All individuals who are the subject of data held by P2V are entitled to:
- Ask what information the company holds about them and why
- Ask how to access the data
- Be informed how to update it
- Be informed as to how the company is meeting its data protection obligations
Subject access requests should be made to Chris Roper by email at [email protected]
P2V are not obliged to issue a data request form.
Individuals will be charged £10 plus VAT per subject access request. The data will be provided normally within 14 working days.
P2V will 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, P2V will disclose requested data provided the request is legitimate, and all possible steps will be taken to ensure this is the case.
P2V 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 right
P2V is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
P2V may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 10th May 2018., reviewed 25th March 2019.
What we collect
We may collect the following information:
- name and job title
- contact information including email address
- demographic information such as postcode, preferences and interests
- other information relevant to customer surveys and/or offers
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
- Internal record keeping.
- We may use the information to improve our products and services.
- We may periodically send promotional emailsabout new products, special offers or other information which we think you may find interesting using the email address which you have provided.
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure,we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
- whenever you are asked to fill in a form on the website, look a the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
- if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at [email protected] or via the email link on the 'contact us' page of this website.
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to:
Peak2Valley, Flat 1, 1 Kelmscott Way, Bognor Regis, West Sussex, PO21 5DU
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.
Effective 25th March 2019