1.1 Everyone has rights with regard to how their personal information is handled. During the course of our activities we will collect, store and process personal information about our customers, suppliers and other third parties. We recognise the need to treat it in an appropriate and lawful manner.
2.1 The types of information that we may be required to handle include details of current, suppliers, customers and others that we communicate with. The information, which may be held on paper or on a computer or other media, is subject to certain legal safeguards specified in the Act. 13/14 of Regulation (EU) (General Data Protection Regulation (the Act) and multiple other regulations. The Act imposes restrictions on how we may use that information.
2.2 This policy has been approved by the Board of Directors (the Board). It sets out our rules on data protection and the legal conditions that must be satisfied in relation to the obtaining, handling, processing, storage, transportation and destruction of personal information
2.3 The Data Protection Compliance Manager is responsible for ensuring compliance with the Act and with this policy. Any questions or concerns about the operation of this policy should be referred in the first instance to the Data Protection Compliance Manager.
2.4 Omega Signs is a Data Controller; contact details are email@example.com.
3. DEFINITION OF DATA PROTECTION TERMS
3.1 Data is information which is stored electronically, on a computer, or in paper-based filing systems.
3.2 Data subjects for the purpose of this policy include all living individuals about whom we hold personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal data.
3.3 Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal).
3.4 Data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They have a responsibility to establish practices and policies in line with the Act. We are the data controller of all personal data used in our business.
3.5 Data users include employees whose work involves using personal data. Data users have a duty to protect the information they handle by following our data protection and security policies at all times.
3.6 Data processors include any person who processes personal data on behalf of a data controller. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on our behalf.
3.7 Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
3.8 Sensitive personal data includes information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions and will usually require the express consent of the person concerned.
4. DATA PROTECTION PRINCIPLES
4.1 Anyone processing personal data must comply with the eight enforceable principles of good practice. These provide that personal data must be:
(a) Processed fairly and lawfully.
(b) Processed for limited purposes and in an appropriate way.
(c) Adequate, relevant and limited to what is necessary.
(d) Accurate and where necessary kept up to date.
(e) Not kept longer than necessary for the purpose.
(f) Processed in an appropriate manner to maintain security.
5. FAIR AND LAWFUL PROCESSING
5.1 The Act is intended not to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject. The data subject must be told who the data controller is (in this case Omega Signs Limited), how to contact controller’s representative (in this case the Data Protection Compliance Manager), the purpose for which the data is to be processed, and the identities of anyone to whom the data may be disclosed or transferred.
5.2 For personal data to be processed lawfully, certain conditions have to be met. These may include, among other things, requirements that the data subject has consented to the processing, or that the processing is necessary for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive personal data is being processed, more than one condition must be met. In most cases the data subject’s explicit consent to the processing of such data will be required.
5.3 Data about customers, suppliers and other third parties may be processed for the following purposes for the purposes of our business.
6. PROCESSING FOR LIMITED PURPOSES
6.1 Personal data will only be processed for the specific purposes notified to the data subject when the data was first collected or for any other purposes specifically permitted by the Act. This means that personal data will not be collected for one purpose and then used for another. If it becomes necessary to change the purpose for which the data is processed, the data subject will be informed of the new purpose before any processing occurs.
6.2 For the purposes outlined in section 6.3, we may collect and process the following information about you:
(a) Information you give us – information that you provide us which may include your name, address, email address and telephone number by filling in forms on our website, or by corresponding with us (by phone, email or otherwise, for example:
(i) when you complete projects or business transactions with us,
(ii) when you report any problems to us,
(iii) when you request support for us; or
(iv) when you complete a survey or questionnaire we send you.
(b) Information we collect about you – information automatically collected when you visit our website for example:
(i) technical information, including the internet protocol (IP) address used to connect your computer to the internet.
(ii) information about your visit, including the full Uniform Resource Locators (URLs), products your viewed or searched for, page interactions information.
(c) Information we receive from third parties – we work with third parties and we may receive information about you from them, for example, business partners, third parties, subcontractors, delivery services, analytical providers, search providers or credit search agencies. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
6.3 We use information held about you for the following purposes:
(a) providing, improving and developing our services;
(b) researching, designing and launching new features and products;
(c) presenting content, information and products in the most effective manner for you.
(d) providing you with updates, materials or information about our services or other types of information
(e) complying with laws and regulations applicable to us in of outside of the EU.
(f) responding or taking part in legal proceedings, including seeking professional advice.
(g) communicating with you and responding to your questions or requests,
(h) for direct marketing purposes.
(i) purposes directly related or incidental to the above.
The information held will be used for legitimate business interest in the continuation of business transactions, with regard to the continuation of business relations and transaction.
Information is also held and used for legal reasons, with regard to the continuation and reporting of business transactions.
7. ADEQUATE, RELEVANT AND NON-EXCESSIVE PROCESSING
7.1 Personal data will only be collected to the extent that it is required for the specific purpose notified to the data subject. Any data which is not necessary for that purpose will not be collected in the first place.
8. ACCURATE DATA
8.1 Personal data will be accurate and kept up to date. Information which is incorrect or misleading is not accurate and steps will therefore be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out-of-date data will be destroyed.
9. DATA RETENTION
9.1 Personal data will not be kept longer than is necessary for the purpose. This means that data will be destroyed or erased from our systems when it is no longer required. The information will be destroyed when it is not required to be held within the business data cycle. For further information please contact the Data Protection Compliance Manager.
10. PROCESSING IN LINE WITH DATA SUBJECTS’ RIGHTS
10.1 Data will be processed in line with data subjects’ rights. Data subjects have a right to:
(a) Request access to any data held about them by a data controller.
(b) Withdraw their consent at any time. Users have the right to withdraw consent where they had previously given their consent to the processing of their personnel data.
(c) Ask to have inaccurate data amended.
(d) Prevent processing that is likely to cause unwarranted substantial damage or distress to themselves or anyone else.
(e) Object to any decision that significantly affects them being taken solely by a computer or other automated process.
11. DATA SECURITY
11.1 We will ensure that appropriate security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
11.2 The Act requires us to put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data may only be transferred to a third-party data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.
11.3 Maintaining data security means guaranteeing the confidentiality, integrity and availability of the personal data, defined as follows:
(a) Confidentiality means that only people who are authorised to use the data can access it.
(b) Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
(c) Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on our central computer system instead of individual PCs.
11.4 Security procedures include:
(a) Entry controls. Any stranger seen in entry-controlled areas should be reported.
(b) Secure lockable desks and cupboards. Desks and cupboards should be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential.)
(c) Computer systems will have adequate password and access controls to ensure only authorised personnel have access.
(d) Methods of disposal. Paper documents should be shredded. Floppy disks and CD-ROMs should be physically destroyed when they are no longer required.
(e) Equipment. Data users should ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended.
12. SUBJECT ACCESS REQUESTS
12.1 A formal request from a data subject for information that we hold about them must be made in writing Any requests should be made to the Data Protection Compliance Manager.
13. PROVIDING INFORMATION TO THIRD PARTIES
13.1 Any enquiries from third parties will be carefully assessed and authorised prior to disclosing any personal information held by us. In particular we will:
(a) Check the identity of the person making the enquiry and whether they are legally entitled to receive the information they have requested.
(b) Ensure the third party put their request in writing so the third party’s identity and entitlement to the information may be verified.
(c) Refer to Data Protection Compliance Manager for assistance in difficult situations.
(d) Where providing information to a third party, do so in accordance with the data protection principles.
14. INTERNATIONAL DATA TRANSFERS
Data is not transferred or accessed across EU borders
If it were, however, adequate levels of data protection would be ensured, including the use of the Privacy Shield for transaction with US businesses.
15. AUTOMATED DECISION-MAKING TOOLS
Automated decision-making tools are not used.
16. MONITORING AND REVIEW OF THE POLICY
16.1 This policy is reviewed by the Board to ensure it is achieving its stated objectives. Recommendations for any amendments should be reported to the Board.
17. COMPLAINTS PROCEDURE
Should you have a complaint please make this in writing to:
Data Protection Compliance Manager, Omega Signs Limited, Newmarket Approach, Leeds, LS9 0RJ
Or Email: firstname.lastname@example.org