Introduction

PHW 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 business general data protection standards – and to comply with the law.

Why this policy exists

This data protection policy ensures WPB:

  • Complies with data protection law and follow good practice
  • Protects the rights of staff and customers
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach

Data protection law

The General Data Protection Regulation 2018 describes how organisations – including PHW – 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 General Data Protection Regulation (GDPR) 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:

  • All staff of PHW
  • All sub contractors, suppliers and other people working on behalf of PHW

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside the General Data Protection Regulation. This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • Plus any other information relating to the individuals

Data Protection Risks

This policy helps to protection PHW from some very real data security risks, including:

  • Breaches of confidentiality – for instance, information being given out inappropriately.
  • Failing to offer choice – for instance, all individuals should be free to choose how the company uses data relating to them.
  • Reputational damage – for instance, the company could suffer if hackers successfully gained access to sensitive data.

Data storage

These rules describe how and where data should be safely stored.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.This guidelines also apply to data that is usually stored electronically but has been printed out for some reason.

Data use

Personal data is of no value to PHW 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:

  • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • Personal data should never be transferred outside of the European Economic Area.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of the data.

Data accuracy

The law requires PHW 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 PHW 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.

  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated.
  • PHW will make it easy for data subjects to update the information PHW holds about them.
  • Data should be updated as inaccuracies are discovered.

Disclosing data for other reasons

In certain circumstances, The General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, PHW will disclose requested data.  However, the we will ensure the request is legitimate, seeking assistance from the Directors and legal advisers where necessary.

Providing information

PHW 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 rights.

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