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Data Protection Policy

 

Context and overview

 

Key details

 

Policy prepared by:   John Horner

Approved by the Board:    14/02/2018

Policy became operational on:    19/02/2018

Next review date:     14/02/2019

 

Introduction

Models 1 needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, 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

This data protection policy ensures Models 1:

Data protection law

The Data Protection Act 1998 describes how organisations — including Models 1 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:

  1. Be processed fairly and lawfully
  2. Be obtained only for specific, lawful purposes
  3. Be adequate, relevant and not excessive
  4. Be accurate and kept up to date
  5. Not be held for any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

 

People, risks and responsibilities

 

Policy scope

This policy applies to:

 

It applies 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:

 

Data protection risks

This policy helps to protect Models 1 from some very real data security risks, including:

 

Responsibilities

Everyone who works for or with Models 1 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 board of directors is ultimately responsible for ensuring that Models 1 meets its legal obligations.

 

The data protection officer, Pauline Rendell, is responsible for:

 

The IT manager, Nick Frost, is responsible for:

The Managing Director, John Horner, is responsible for:

protection principles.

General staff guidelines

 

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

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:

 

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

 

Data use

Personal data is of no value to Models 1 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:

Data accuracy

The law requires Models 1 to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort Models 1 should put into ensuring its accuracy.

 

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.

 

Subject access requests

All individuals who are the subject of personal data held by Models 1 are entitled to:

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, addressed to the data controller at john@models1.co.uk. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.

The data controller 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, Models 1 will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

 

Providing information

Models 1 aims to ensure that individuals are aware that their data is being
processed, and that they understand:

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. A version of this statement is also available on the company’s website.]