Introduction
Author Laura Greenwood needs to gather and
use certain information about individuals. This includes customers, suppliers,
business contacts, employees and other people Author Laura Greenwood has relationships
with or may need to contact.
This policy describes how this
personal data must be collected, handled and stored to meet Author Laura Greenwood’s data
protection standards and to comply with the law.
Why this policy exists
This data protection policy
ensures Author Laura Greenwood:
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Complies with data protection law and follows good practice
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Protects the rights of staff, customers and partners
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Is open about how it stores and processes individuals’
data
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Protects itself from the risks of a data breach
Data Protection Law
The Data Protection Act (entering into law
25th May 2018) describes how organisations - including Author Laura Greenwood - 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 the following principles. These say that personal data must:
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Be processed fairly and lawfully
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Be obtained only for specific, lawful purposes
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Be adequate, relevant and not excessive
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Be accurate and kept up to date
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Not be held for any longer than necessary
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Processed in accordance with the rights of data
subjects
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Be protected in appropriate ways
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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:
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The head office of
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All branches of
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All staff and volunteers of
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All contractors, suppliers and other people working on
behalf of Author Laura Greenwood.
It applies to all data the
company holds relating to identifiable individuals. This can include:
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Names of individuals
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Postal addresses
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Email addresses
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Telephone numbers
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Cookie tracking data
Data Protection Risks
This policy helps protect Author Laura Greenwood from data security risks, including:
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Breaches of confidentiality (e.g. information being
given out inappropriately
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Failing to offer choice (e.g. all individuals should be
free to choose how the company uses data relating to them)
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Reputational damage (e.g. the company could suffer if
hackers successfully gained access to sensitive data.)
Responsibilities
Everyone who works for or with Author Laura Greenwood has 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.
General Staff Guidelines
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The only people able to access data covered by this
policy should be those who need it for their work
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Data should not be shared informally. When access to
confidential information is required, employees can request it from their line
managers.
- Author Laura Greenwood will provide training to all employees to
help them understand their responsibilities when handling data
- All data must be kept secure, by taking
sensible precautions and following the guidelines below.
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In particular, strong passwords must be used and they
should never be shared.
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Personal data should not be disclosed to unauthorised
people, either within the company or externally
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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.
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Employees should request help from their line manager
or data protection officer if they are unsure about any aspect of data
protection.
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:
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When not required, the paper or files should be kept in
a locked drawer or filing cabinet.
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Employees should make sure paper and printouts are not
left where unauthorised people could see them
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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:
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Data should be protected by strong passwords that are
changed regularly and never shared between employees.
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If data is stored on removable media (like a CD or
DVD), these should be kept locked away securely when not being used.
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Data should only be stored on designated drives and
servers and should only be uploaded to an approved cloud computing service.
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Servers containing personal data should be sited in a
secure location, away from general office space.
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Data should be backed up frequently. Those backups
should be tested regularly, in line with the company’s standard backup
procedures.
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Data should never be saved directly to laptops or other
mobile devices like tablets or smart phones
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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 Author Laura Greenwood 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:
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When working with personal data, employees should
ensure the screens of their computers are always locked when left unattended.
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Personal data should not be shared informally. In
particular, it should never be sent by email, as this form of communication is
not secure.
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Data must be encrypted before being transferred
electronically. The IT manager can explain how to send data to authorised
external contacts.
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Personal data should never be transferred outside of
the European Economic Area
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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 Author Laura Greenwood 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 Author Laura Greenwood 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.
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Dara will be held in as few places as necessary. Staff
should not create any unnecessary additional data sets.
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Staff should take every opportunity to ensure data is
updated. For instance, by confirming a customer’s details when they call.
- Author Laura Greenwood will make it easy for data subjects to
update the information they hold about them. For instance, via the company
website.
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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.
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It is the marketing manager’s responsibility to ensure
marketing databases are checked against industry suppression files every six
months.
Subject Access Requests
All individuals who are the
subject of personal data held by Author Laura Greenwood are entitled to:
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Ask what information the company holds about them and
why.
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Ask how to gain access to it
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Be informed how to keep it up to date
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Be informed how the company is meeting the 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 lauragreenwood@authorlauragreenwood.co.uk .
The data controller can supply a standard request form, although individuals do
not have to use this.
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 the information.
The right to be forgotten
All individuals who are the
subject of personal data held by Author Laura Greenwood are entitled to enact the right
to be forgotten, upon which all personal data will be removed from Author Laura Greenwood’s databases.
The right to be forgotten
requests from individuals should be made by email, addressed to the data
controller at lauragreenwood@authorlauragreenwood.co.uk .
The data controller will always
verify the identity of anyone invoking the right to be forgotten.
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, Author Laura Greenwood 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 advisors where necessary.
Providing Information
Author Laura Greenwood aims to ensure that
individuals are aware that their data is being processed, and that they
understand:
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How the data is being used
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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.
Author Laura Greenwood also uses the following sites & tools, and for
reference, has linked their privacy policies: