Leisure Lites Ltd needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the business 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.
Purpose of this policy
This policy ensures that Leisure Lites Ltd
– Complies with data protection law and follows good practice
– Protects the rights of staff, customers and partners
– Is open about how it stores and processes individual’s data
– Protects itself from the risks of a data breach
Data Protection Law
The General Data Protection Regulations (GDPR) describes how organisations, including Leisure Lites Ltd, must collect, handle and store personal information. GDPR replaces the Data Protection Act 1998 and must be implemented by 25th May 2018.
These rules apply regardless of whether data is stored electronically, on paper or other materials.
To comply with the law personal information must be collected and used fairly, stored safely and not disclosed unlawfully. The process of how we collect and use the data must be documented.
The Data Protection Act is underpinned by six important principles. These say that personal data must:
– Be processed lawfully, fairly and in a transparent manner in relation to individuals
– Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
– Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having
regard to the purposes for which they are processed, are erased or rectified without delay
– Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is
processed; personal data may be stored for longer periods insofar as the personal data processed solely for archiving purposes in the public
interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and
organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
– Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and
against accidental loss, destruction or damage, using appropriate technical or organisational measures.
This policy applies to:
– All Leisure Lites Ltd employees
– All contractors, suppliers and other people working on behalf of Leisure Lites Ltd
It applies to all data that the company holds relating to identifiable individuals, which includes, but is not restricted to:
– Names of individuals
– Postal addresses
– Email addresses
– Telephone numbers
– Any information held relating to individuals necessary to provide a service
Data Protection Risks
This policy helps to protect Leisure Lites Ltd from data security risks, including:
– Breaches of confidentiality – information being given out inappropriately
– Failing to offer choice – individuals should be free to choose how the Company uses data relating to them
Everyone who works for or with Leisure Lites Ltd has some responsibility for ensuring data is collected, stored and handled appropriately. Each member of staff 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 responsibilities:
– The Directors are ultimately responsible for ensuring that Leisure Lites Ltd meets it’s legal obligations
– The data protection officer, Lisa Hollingworth (Director), is responsible for :
– Keeping the Director’s updated about data protection responsibilities, risks and issues
– Reviewing all data protection procedures and related policies within an agreed schedule
– Arranging data protection training and advice for the people covered by this policy
– Dealing with requests from individuals to see the data Leisure Lites Ltd holds about them (Subject Access Requests)
General Employee Guidelines
– Leisure Lites Ltd 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
– Strong passwords should be used, where appropriate, and never shared
– Personal data should not be disclosed to unauthorised people, either within the company or externally
– Employees should request help from the Data Protection Officer if they are unsure about any aspect of data protection
These rules describe how and where data should be stored safely. Questions about storing data safely should be directed to the Office Manager (Charlotte Purdy) or Data Protection Officer (Lisa Hollingworth).
Leisure Lites Ltd generally operates a paperless office environment; however, when data is stored on paper it should be kept in a secure place where unauthorised people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
– Paper should be kept in a locked drawer or filing cabinet, when not being used
– Employees should make sure paper and printouts are not left where unauthorised people could see them, such as on a printer or in their vehicle
– Data printouts and documents that are no longer required should be shredded for secure disposal
Where 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 and never shared between employees or external persons
– If data is stored on removable media, like CD or USB stick, these should be kept locked away securely when not being used
– Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing service.
– Data should be backed up frequently. Those back- ups should be tested regularly, in line with the Company’s standard back up procedures
– All computers containing data should be protected by approved security software and a firewall
It is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or inadvertent breach of confidentiality:
– Personal data should not be shared informally with unauthorised people
– Employees must ensure that they safeguard customer personal information when working on sites
– Employees must ensure that personal data is not displayed on desks or computer screens when external visitors attend the office
The law requires Leisure Lites Ltd 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.
– Data should be updated when inaccuracies are discovered. For instance, if a customer can no longer be contacted on their recorded phone number it should be removed from the records.
Subject Access Requests
All individuals who are the subject of personal data held by Leisure Lites Ltd are entitled to:
– Ask what information the company holds about them and why it is holding it
– 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 (SAR).
SAR’s from individuals should be in writing, either by email or letter, addressed to the Office Manager. The company will aim to respond within 14 days.
The Office Manager will always verify the identity of anyone making a SAR before handing over any information.
Disclosing data for other reasons
In certain circumstances GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances Leisure Lites Ltd will disclose requested data. However, the company will ensure the request is legitimate, seeking legal and professional advice where necessary.
Leisure Lites Ltd aims to ensure that individuals are aware their data is being processed and that they understand:
– How their data is being used
– How to exercise their rights
Leisure Lites Ltd
Unit 1, Sycamore House
Morgreen Industrial Park
Tel: 01773 712 121
This policy was last updated on 23rd May 2018.