Introduction

Established 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 law.

Why this policy exists

This data protection policy ensures Established:
• Complies with general data protection legislation and follow 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

The General Data Protection Regulation

The General Data Protection Regulation 2016 (GDPR) is a significant regulation in EU law on data protection and privacy for all individuals within the European Union. It is how Established manages data protection as a corporate issue by documenting the personal data held; state where it came from and who the data is shared with. Established complies with all of the GDPR principles. Personal data shall be:
1. processed lawfully, fairly and in a transparent manner in relation to individuals
2. collected for specified, explicit and legitimate purposes
3. adequate, relevant and limited to what is necessary
4. accurate and, where necessary, kept up to date
5. kept for no longer than is necessary
6. Processed in a manner that ensures appropriate security of the personal data

People, risks and responsibilities
Policy scope

This policy applies to:
• The head office of Established
• All staff of Established
• All contractors, suppliers and other people working on behalf of Established
• The systems and processes the above people have access to
It applies to all data that the company holds relating to identifiable individuals and the purposes for which we use the detailed information see our Privacy Policy

Data protection risks

This policy helps to protect Established 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 Established has some 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 GDPR principles.
The key people responsible and their definitions:
Accountable: Managing Director - the person who has ultimate accountability and authority for the policy
Responsible: Data Protection Officer – the person responsible for developing and implementing the policy
Consulted: Directors – the people to be consulted prior to final policy implementation or amendment
Informed: Staff (including temporary staff) – the people to be informed after policy implementation or amendment

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Data Protection Officer.
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 with 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 Established 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.
• 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 regulation requires Established 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 Established 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.
• Established will make it easy for data subjects to update the information Established holds about them.
• 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 is the Directors 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 Established 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 protection officer at data@establishedmodels.com. The data protection officer can supply a standard request form, although individuals do not have to use this. The data protection officer will aim to provide the relevant data within 14 days.
The data protection officer 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, Established will disclose requested data. However, the data protection officer will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing information

Established 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 policy, setting out how data relating to individuals is used by the company.