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The EU General Data Protection Regulation (“GDPR”) came into force on 25 May 2018. The new Regulation aims to standardise data protection laws and processing across the EU, giving people greater rights to access and control their personal information.
Holiday at Home needs to gather and use certain information about individuals. These can include customers, suppliers, business contracts, 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. Holiday at Home is committed to ensuring protection of all personal information that we hold, and to provide and to protect all such data. We recognise our obligations in updating and expanding this program to meet the requirements of GDPR.
Why this policy exists
This data protection policy ensures that Holiday at Home:
-Complies with the data protection law and follows good practice.
-Protects the rights of staff, customers and partners.
-Is open about how its doors and processes individual’s data.
-Protects itself from the risk of data breach.
Data protection law
The Data Protection Act 1998 describes how open organisations must collect, handle and store personal information. These rules must apply regardless of whether the 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 disclose unlawfully. The data protection act is underpinned by eight important principles these say that personal data must:
-Be processed fairly and lawfully.
-Be obtained only for specific, lawful purposes.
-Be adequate, relevant and not excessive.
-Be accurate and kept up to date.
-Not be held any longer than necessary.
-Processed in accordance with the rights of data subjects.
-Be protected in appropriate ways.
-Not be transferred outside of the European economic area, unless that country or territory also ensures adequate level of protection.
People, risks and responsibilities
This policy applies to:
-The head office of Holiday at Home.
-All branches of Holiday at Home.
-All staff and volunteers of Holiday at Home.
-All contractors, suppliers and other people working on behalf of Holiday at Home.
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:
-Names of individuals.
-Any other information relating to individuals.
Data protection risks
This policy helps protect Holiday at Home from some very real data security risks, including:
-Breaches of confidentiality. For instance, information being given out in appropriately.
-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 too sensitive data.
Everyone who works for Holiday at Home 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, Holiday at Home Directors are ultimately responsible for ensuring that Holiday at Home meets its legal obligations.
The company Director’s are responsible for:
-Keeping the directors updated about data protection responsibilities, risks and issues.
-Reviewing all data protection procedures and related policies, in line with an agreed schedule. -Arranging data protection training and advice for people covered by this policy.
-Handling data protection questions from staff and anyone else covered in this policy.
-Dealing with requests from individuals to see the data holiday at home holds about them.
-Checking and approving any contracts or agreements with third parties that may handle the company sensitive data.
-Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
-Performing regular checks and scans to ensure that security hardware and software is functioning properly.
-Evaluating any for third-party services that the company is considering using to store and process data.
-Approving all data protection statements attached to communications such as emails and letters addressing any data protection queries from journalists and media outlets like newspapers.
-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 that work.
-Data should not be shared informally.
-When access to confidential information is required, employees can request it from their line managers.
-Holiday at Home 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 under authorise people, either within the company or externally.
-Data should be reviewed regularly 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 if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to William Stephenson.
-When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
-These guidelines also appear to data that he usually stored electronically has been printed out for some reason.
-When not required, the paper or files should be kept in a locked drawer or cupboard.
-Employees should make sure paper and printouts are not left where on authorised people could see them, like a printer.
-Data printouts should be shredded and disposed of securely when no longer required.
-When data is stored electronically, it should 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 such as a USB, these should be kept locked away securely when not being used.
-Data should only be stored on designated drivers and servers and should not be uploaded to any on approved computing services.
-Servers containing personal data should be cited in a secure location, away from general office space. (Currently not applicable).
-Data should be backed up frequently. Those backups should be tested regularly in line with company standard back up procedures.
-Data should never be saved directly to laptops or other mobile devices such as tablets or phones.
-All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Holiday at Home unless the business can make use of it. However, it is when personal data is access and used to be at the greatest risk of loss, corruption or theft:
-When working with personal data, employees should ensure that 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 it before been transferred electronically.
-The company IT contractor can explain how to send data to authorised external contacts.
-Personal data should never be transferred outside the European economic area.
-Employees should not save copies of their personal data to their own computers.
-Always access an update the central copy of any data.
-The law requires Holiday at Home to take reasonable steps to ensure that data is kept accurate and up to date.
-The more important it is that personal data is accurate, the greater effort Holiday at Home should put into ensuring its accuracy.
-It is the responsibility of all employees who work with data to take reasonable steps to ensure that data is accurate and up-to-date as possible.
-Data will be held in as fewer 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.
-Holiday at home will make it easy for data subjects to update their information. For instance, via the online booking system.
-Data should be updated as inaccuracies are discovered. From instance, if a customer could no longer be reached on their stored telephone number, it should be removed from the database.
-It is the marketing manager‘s responsibility to ensure marketing databases are checked against in the streets of depression files every six months.
Subject access request
All individuals who are the subject of personal data held by Holiday at Home are entitled to:
-Ask what information the company hold 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 request from individual should be made by email, addressed to William Stephenson at [email protected]. Individuals will be charged at £10 per subject access request the data controller will aim to provide the relevant data within 14 days. Holiday at Home 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, Holiday at Home will disclose the requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the companies’ legal advisers when necessary.
Holiday at Home aims to ensure that the individuals are aware that the data is being processed, and that they understand:
-How the data is being used.
-How to exercise that right.
To these ends, the company has a privacy statement, setting out how data relating to the individuals used by the company this is available on request.
Policy prepared by William Stephenson, Director at Holiday at Home Ltd.
Policy became operational on: 25/05/2018