General Data Protection Policy

Context and overview

Key details

Policy prepared by:                                        R Hicks

Policy became operational on:                    15/05/2018

Next review date:                                           15/05/2020

 

Context and overview   1

Key details  1

Introduction  3

Why this policy exists  3

Data  3

How we gather your data  3

Data protection law   4

People, risks and responsibilities  4

Policy scope  4

Data protection risks  5

Responsibilities  5

General Employees guidelines  6

Data storage  6

Data use  7

Data accuracy  7

Your right to access information we store about you (Subject Access Requests) 8

Disclosing data for other reasons  8

Providing information  8

Your right to rectification  9

Your right to have data erased  9

Your right to object 9

How long we keep your data  9

Third party applications and their GDPR policies  9

 

Introduction

Ashbee Solutions Limited needs to gather and use certain information about individuals.

These can include customers, 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 Ashbee Solutions Limited:

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

Data

How we gather your data

Customers: when you contact us, we will make a record of your name, address, email address, phone numbers and the property that the works are to take place at. This will be stored on a password protected database which only our employees have access to. This information will be used to prepare quotations and, if works go ahead, to prepare other documents relating to the works such as method statements, risk assessments and ASB5 notifications.

We do not pass or sell your information to any third parties except where required by regulatory bodies – such as the Health and Safety Executive and Environment Agency – to allow us to carry out our work.

If you do not go ahead any quoted works, your details will be kept for 3 years against your quotation so that if you call us at a later date we are able to provide a copy of the quotation; unless you contact us and ask us to delete the data. If you decide to go ahead with asbestos removal works, we are required by law to keep records of invoices for a minimum of 6 years from the date of invoice. See https://www.gov.uk/running-a-limited-company/company-and-accounting-records for more information.

Employees and subcontractors: when you become an employee or subcontractor of Ashbee Solutions Limited, you will be required to provide several elements of personal information to enable us to deal with PAYE, National Insurance and The Illegal Working Compliance Orders Regulations 2016. This information will be stored for 6 years after your employment ceases as required by HMRC.

If you are an asbestos operative, you will be required to provide us with other documentation and certification to show that you are qualified and allowed to work with asbestos containing materials. It is a requirement that we store this information for a minimum of 40 years or until you reach your 80th birthday. See http://www.hse.gov.uk/health-surveillance/record-keeping/index.htm for more information.

Information will be stored either on a secure network server at our head office address, or in a secure (locked and alarmed) filing cabinet room in paper form.

 

Data protection law

The Data Protection Act 1998 describes how organisations – including Ashbee Solutions Limited – 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:

  • The head office of Ashbee Solutions Limited
  • All employees of Ashbee Solutions Limited
  • All contractors, suppliers and other people working on behalf of Ashbee Solutions Limited

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.

Data protection risks

This policy helps to protect Ashbee Solutions Limited 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.

 

Responsibilities

Everyone who works for or with Ashbee Solutions Limited has some responsibility for ensuring data is collected, stored and handled appropriately.

Each person 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 Managing Director, Rebecca Berry, is ultimately responsible for ensuring that Ashbee Solutions Limited meets its legal obligations.

The Managing Director is responsible for:

  • Reviewing all data protection procedures and related policies, in line with an agreed schedule
  • Arranging data protection training and advice for the people covered by this policy where required
  • Handling data protection questions from Employees and anyone else covered by this policy
  • Dealing with requests from individuals to see the data Ashbee Solutions Limited holds about them (also called ‘subject access requests’).
  • Checking and approving any contracts or agreements with third parties that may handle the Company’s sensitive data.
  • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
  • Performing regular checks and scans to ensure security hardware and software is functioning properly, where required and where this is not already carried out by a 3rd party software provider
  • Evaluating any third-party services the Company is considering using to store or process data. For instance, cloud computing services.

General Employees guidelines

  • The only people able to access data covered by this policy should be those who need it for their work.
  • Data should not be shared informally. When access to confidential information is required, Employees can request it from their line managers.
  • Ashbee Solutions Limited 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 and following the guidelines below.
  • In particular, strong passwords must be used and they should never be shared.
  • Two-factor authorisation should be used wherever possible.
  • Personal data should not be disclosed to unauthorised people, either within the Company or externally.
  • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
  • Employees should request help from their Section Leader or the data protection officer if they are unsure about any aspect of data protection.
  • You must notify the Information Commissioner Office within 72 hours of any data breach, and you may also have to notify your young people, parents and employees.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the 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 not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer or open folder on a desk.
  • Data printouts should be shredded and disposed of securely when no longer required.
  • When 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.
  • If data is stored on removable media (like a CD or DVD), 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 services.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Data should be backed up frequently. Those backups should be tested regularly, in line with the Company’s standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to Ashbee Solutions Limited unless the Company 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.
  • Data must be encrypted before being transferred electronically. Ritchie Hicks can explain how to send data to authorised external contacts.
  • 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 any data.

Data accuracy

The law requires Ashbee Solutions Limited 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 Ashbee Solutions Limited 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. Employees should not create any unnecessary additional data sets.
  • Employees should take every opportunity to ensure data is updated.
  • Ashbee Solutions Limited will make it easy for data subjects to update the information Ashbee Solutions Limited holds about them. For instance, via the Company website.
  • Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.

Your right to access information we store about you (Subject Access Requests)

All individuals who are the subject of personal data held by Ashbee Solutions Limited are entitled to:

  • Ask what information the Company holds about them and why
  • 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.

Subject access requests from individuals should be made by email, addressed to the data controller at help@solutions.ashbee.org. 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. For example, requesting forms of photo identification such as a passport or drivers licence.

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, Ashbee Solutions Limited will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the Company’s legal advisers where necessary.

Providing information

Ashbee Solutions Limited 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

To these ends, the Company has a privacy statement, setting out how data relating to individuals is used by the Company.

Your right to rectification

Individuals have the right to have their information corrected if they believe it is factually inaccurate – this is known as the right to rectification.

Your right to have data erased

The right to erasure is also known as ‘the right to be forgotten’. In certain circumstances, it allows people to instruct organisations to delete or remove their personal data.

Your right to object

We do not sell information to any third parties, except the Scout Association. You have the right to object to the processing of your personal data at any time.

Third party applications and their GDPR policies

Ashbee Solutions Limited use the following third party applications to store data or contact parents:

  • Disclosure and Barring Service – https://www.gov.uk/government/publications/dbs-privacy-policies
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