Your privacy is important to us.
We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.
We will collect and use personal information solely for fulfilling those purposes specified by us and for other ancillary purposes, unless we obtain the consent of the individual concerned or as required by law.
Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
We will protect personal information by using reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
Upon request, we aim to make available to customers information about our policies and practices relating to the management of personal information within 30 days.
We will only retain personal information for as long as necessary for the fulfilment of those purposes.
Full Version - Data protection policy
Context and overview
Policy prepared and approved by: Martin Foreman
Date approved: 21.05.18
Policy became operational on: 21.05.18
Next review date: 21.05.19
Acorn Picture Framing 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 business’s data protection standards — and to comply with the law.
Why this policy exists
This data protection policy ensures Acorn Picture Framing:
• 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 individuals’ data
• Protects itself from the risks of a data breach
Data protection law
The General Data Protection Regulation 2016/679 describes how organisations — including Acorn Picture Framing — 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 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 EU, unless that country or territory also ensures an adequate level of protection
People, risks and responsibilities
This policy applies to:
• The business Acorn Picture Framing
• All staff and volunteers of Acorn Picture Framing
• All contractors, suppliers and other people working on behalf of Acorn Picture Framing
It applies to all data that the business holds relating to living individuals, even if that information technically falls outside of the General Data Protection Regulation 2016/679. This can include:
• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Any other information relating directly or indirectly to individuals
Data protection risks
This policy helps to protect Acorn Picture Framing 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 business uses data relating to them.
• Reputational damage:
For instance, the business could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with Acorn Picture Framing has some responsibility for ensuring data is collected, stored and handled appropriately. The owners are ultimately responsible for ensuring that Acorn Picture Framing meets its legal obligations.
The owners are responsible for:
o Keeping updated about data protection responsibilities, risks and issues.
o Reviewing all data protection procedures and related policies, in line with an agreed schedule.
o Arranging data protection training and advice for the people covered by this policy.
o Handling data protection questions from staff and anyone else covered by this policy.
o Dealing with requests from individuals to see the data Acorn Picture Framing holds about them (also called ‘subject access requests’).
o Checking and approving any contracts or agreements with third parties that may handle the business’s sensitive data.
o Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
o Performing regular checks and scans to ensure security hardware and software is functioning properly.
o Evaluating any third-party services the business is considering using to store or process data. For instance, cloud computing services.
o Approving any data protection statements attached to communications such as emails and letters.
o Addressing any data protection queries from journalists or media outlets like newspapers.
o Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
General staff 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.
• Acorn Picture Framing 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.
• Personal data should not be disclosed to unauthorised people, either within the business 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 line manager or the data protection officer if they are unsure about any aspect of data protection.
• 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.
• 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 business’s standard backup procedures.
• All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Acorn Picture Framing 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.
• Data must be encrypted before being transferred electronically 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.
The law requires Acorn Picture Framing 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 Acorn Picture Framing 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. For instance, by confirming a customer’s details when they call.
• Acorn Picture Framing will make it easy for data subjects to update the information Acorn Picture Framing holds about them. For instance, via the business 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.
• It should be ensured that 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 Acorn Picture Framing are entitled to:
• Ask what information the business 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 business is meeting its data protection obligations.
If an individual contacts the business requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to firstname.lastname@example.org. The data controller can supply a standard request form, although individuals do not have to use this.
Individuals cannot be charged to honour a subject access request. The data controller will aim to provide the relevant data within 30 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 General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Acorn Picture Framing will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance of legal advice where necessary.
Acorn Picture Framing 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 business has a privacy statement, setting out how data relating to individuals is used by the business.