F4G GDPR


Data Protection Policy

May 2018

 

Policy became operational on: 07/05/2018          
Next review date: 07/05/2019

 

Introduction

Foundations4growth Ltd (F4G) 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 company’s data protection standards — and to comply with the GDPR.

 

Why this policy exists

This data protection policy ensures F4G Ltd:

  • Understands what GDPR is and how it impacts us
  • Understands individuals rights around personal data
  • 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

F4G Ltd is committed to a policy of protecting the rights and privacy of individuals, including, staff, associates, clients and customers, in accordance with the General Data Protection Regulation (GDPR) May 2018. 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.

 

F4G Ltd understand that 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 for any longer than necessary
  • Processed in accordance with the rights of data subjects
  • Be protected in appropriate ways
  • Not be transferred outside the European Economic Area (EEA), unless that          country or territory also ensures an adequate level of protection.

 

Under the GDPR individuals have:

  • The right to access
  • The right to be forgotten
  • The right to data portability
  • The right to be informed
  • The right to have information corrected
  • The right to restrict processing
  • The right to object
  • The right to be notified

 

General Data Protection

This piece of legislation comes in to force on the 25th May 2018. The GDPR regulates the processing of personal data, and protects the rights and privacy of all living individuals, for example by giving all individuals who are the subject of personal data a general right of access to the personal data which relates to them.

Individuals can exercise the right to gain access to their information by means of a ‘subject access request’. Personal data is information relating to an individual and may be in hard or soft copy (paper/manual files; electronic records; photographs), and may include facts or opinions about a person.

For more detailed information on these Regulations see the Data Protection Data Sharing Code of Practice (DPCoP) from the Information Commissioner’s Office (ICO).

 

People, risks and responsibilities

Policy scope

This policy applies to:-

  • The head office of F4G Ltd
  • All staff of F4G Ltd
  • All contractors, suppliers and other people working on behalf of F4G Ltd

 

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. This can include:-

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • Passport Information
  • …plus any other information relating to individuals.

 

Below is a list of personal data that we believe will be affected at F4G Ltd:-

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


Data protection risks

This policy helps to protect F4G Ltd from data security risks, including:-

  • Breaches of confidentiality. For instance, the information being given out inappropriately
  • Failing to offer a 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 F4G Ltd has some responsibility for ensuring data is collected, stored and handled appropriately.

 

Everyone that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

 

However, there are key areas of responsibility:

  • The directors are ultimately responsible for ensuring that F4G Ltd meets its legal obligations.
  • The role of data protection officer is held jointly by the Directors and is responsible for:
  • Reviewing all data protection procedures and related policies, in line
  • with an agreed schedule
  • Arranging data protection advice for the people covered by this policy
  • Handling data protection questions from anyone covered by this policy
  • Dealing with requests from individuals to see the data that F4G Ltd 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
  • Not to retain personal data for longer than is necessary to ensure compliance with the legislation and any other statutory requirements. This means F4G Ltd will undertake a regular review of the information held. F4G Ltd will dispose of any personal data in a way that protects the rights and privacy of the individual concerned (e.g. secure electronic deletion, shredding and disposal of hard copy files as confidential waste).

 

Re IT, the Directors are also responsible for:-

  • 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.

 

The Directors are also responsible for:-

  • Approving any data protection statements attached to communications such as emails and letters.

 

General 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
  • Employees should keep all data secure, by taking sensible precautions and following the guidelines below:-
  • Passwords must be used and they should never be shared
  • Personal data should not be disclosed to unauthorised people, either within the company or externally
  • Printouts not to be left on printers
  • Ensure offices are locked when not occupied
  • Ensure pc is locked when away from the desk
  • Ensure pc is shut down at end of the working day
  • 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

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. F4G Ltd keep hard copies of personal data in a filing cabinet which is kept locked. This can only be accessed by the Directors.

 

The following also applies 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 passwords
  • 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 approved cloud computing services.
  • Computers containing personal data are sited in a secure location
  • Data should be backed up frequently
  • All servers and computers containing data should be protected by approved security software

 

Data use

  • 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
  • Personal data should never be transferred outside of the European Economic Area

 

Client Data

Because we would not be the main controller of our client’s data, they would have the sole responsibility for the personal data on their customers. Whilst we would follow our data protection procedures written in this policy, e.g. storing data safely, not passing on data to other people, ultimately, we will follow the client’s data policy guidelines which they stipulate.

 

Data accuracy

The law requires F4G Ltd to take reasonable steps to ensure data is kept accurate and up to date.

 

  • Data will be held in as few places as necessary
  • F4G Ltd will make it easy for data subjects to update the information F4G Ltd 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

 

Subject access requests

All individuals who are the subject of personal data held by F4G Ltd 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 of 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 Jan McLean-Smith at jan@foundations4growth.co.uk. Jan will aim to provide the relevant data within 14 days.

If they want the information to be deleted F4G Ltd will:-

  • Check for electronic and hard copies
  • Check on company computers

 

The data controller will always verify the identity of anyone making a subject access request before handing over any information. This will be done by:

  • Calling the person to confirm who they are.

 

The process that F4G Ltd will carry out to ensure we are complying with subject access requests is:-

  • Confirm if the individual is who they say they are
  • Check all platforms for electronic copies
  • Send any data we have on the individual
  • Delete or update the information we have
  • Send an email to confirm deletion or updating of information
  • Update data log of the subject access request

 

Safeguarding personal data

F4G Ltd will ensure the safeguarding of personal data held by the company by:-

  • Having password protected computers
  • Keeping all hard copies of personal data locked with limited access
  • Locking the offices
  • Getting consultants and associates to sign confidentiality agreements

 

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, F4G Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.

 

Email

Under the Regulation of Investigatory Powers Act 2000, Lawful Business Practice Regulations, any email sent to or from F4G Ltd may be accessed by someone other than the recipient for system management and security purposes.

 

Process for review

This policy will be updated as necessary to reflect best practice or future amendments made to the General Data Protection Regulation (GDPR) May 2018 and Data Protection Act 1998.

 

 

Glossary

 

Data Controller

A person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. The term comprises not only individuals but also organisations such as companies and other corporate bodies of persons.

 

Data processor

Any person who processes the data on behalf of the data controller.

 

Data subject

Any living individual who is the subject of personal data.

 

Personal data

Information which relates to a living individual who can be identified from that data, from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.

 

Processing

Any operation or set of operations performed upon personal data, whether or not by automatic means. These include collecting, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.

 

Sensitive personal data

Personal data which consists of data related to the data subject’s racial or ethnic origin political opinions, religious or similar beliefs, trade union membership, physical or mental health, sexual life, the commission of offences or criminal proceedings.

 

 

Address

Phone number

DOB

Passport

Email addresses

Bank details

Individual

What data held?

Where

Who has access?

Address

Phone number

DOB

Passport

Email addresses

Bank details
Rates & payments

Directors

Associates

 

Addresses

Phone numbers

Email addresses

 

Clients and

Prospects

 

 

 

Hard copies

Computer

Label writer

 

 

Directors

Directors

Directors

Hard copies

Computer

 

Hard copies

Computer

 

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