Data Protection Policy
- Policy prepared by: Martin Pownall
- Approved by board of Directors: 15th March 2018
- Policy became operational on: 15th March 2018
- New release date: 15th March 2019
- Complies with data protection law and follows good practice
- Protects the rights of staff, customers and partners
- Is open about how it stores and processors individual’s data
- Protects itself from the risks of data breach
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and 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
- The head office of Port Engineering Services
- All branches of Port Engineering Services
- All staff and volunteers of Port Engineering Services
- All contractors, suppliers and other people working on behalf of Port Engineering Services
- Name of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Plus any other information relating to individuals
- 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
- The board of Directors is ultimately responsible for ensuring Port Engineering Services meets its legal obligations.
- Keeping the board 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 the people covered by this policy
- Handling data protection questions from staff and anyone else covered by this policy
- Dealing with requests from individuals to see the data Port Engineering Services holds about them (also called “subject access requests”
- Checking and approving any contracts and agreements with third parties that may handle the company’s sensitive data
- Ensuring all systems, services and equipment used for storing data meets acceptable security standards
- Performing regular checks and scans to ensure security hardware and software is functioning properly
- Evaluating any third party services the company is considering using to store or process data. For example cloud computing services
- Approving any data protection statements attached to communications such as emails and letters
- Addressing any data protection queries from journalists or media outlets like newspapers
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles
- Data should not be shared informally. When access to confidential information is required, employees can request it form their line managers
- Port Engineering Services 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 company 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 data protection officer if they are unsure about any aspect of data protection
- When not required, the paper or files should be kept in a locked drawer or filling 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
- 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 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 firewall services
- 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. The IT manager can explain how to send data 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
- Data will be held in as few places as necessary. Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call
- Port Engineering Services will make it easy for data subjects to update the information Port Engineering Services 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
- It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months
- 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
- How data is being used and stored
- How to exercise their rights
- Port Engineering Services also operate a controlled Confidentiality document FO- 21 to which each employee or subcontractor MUST sign before being allowed to operate under Port Engineering Services. This document FO-21 contractually binds each employee by law so to do so, that no information or data will be disclosed to anyone person or company in any unauthorised manner outside of Port Engineering Services. (A copy of this document is attached to this policy for reference).
Port Engineering Services needs to gather and use certain information about individuals and company information.
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 collated, 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 that Port Engineering Services:
Data Protection Law
The Data Protection Act 1998 describes how organisations including Port Engineering Services must collect, handle and store personal data.
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 Data Protection Act is underpinned by eight important principles. These say that personal data must:
People, risks and responsibilities
This policy applies to:
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:
Data protection risks
This policy helps to protect Port Engineering Services from some very real data security risks, including:
Everyone who works for Port Engineering Services has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that this is handled and processed in line with this policy and data protection principles. However, these people have key areas of responsibility:
The data protection officer “Martin Pownall” is responsible for:
The IT manager “Peter Angus” is responsible for:
The Marketing Manager is responsible for:
General staff guidelines
The only people able to access data covered by this policy should be those who need it for their work
These rules describe how and where the data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
When data is stored in paper format, 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 data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
Personal data is of no value to Port Engineering Services 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:
The law requires Port Engineering Services to take responsible 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 Port Engineering Services should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take responsible steps to ensure it is kept as accurate and up to date as possible.
Subject access requests
All individuals who are the subject of personal data held by Port Engineering Services are entitled to:
If an individual contacts the company requesting this information, this is called a subject access requirement.
Subject access requirements from individuals should be made by email, addressed to the data controller at firstname.lastname@example.org
The data controller can supply a standard request form, although individuals do not have use of this.
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 Data Protection Act allows personal data be disclosed to law enforcement agencies without consent of the data subject.
Under these circumstances, Port Engineering Services will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance form the board and from the company’s legal adviser where necessary.
Port Engineering Services aims to ensure that individuals or company’s are aware that their data is being processed, and that they understand:
To these ends the company has a privacy statement, setting out how data relating to individuals is used by the company.
On behalf of Port Engineering Services:
18 Witney Way, Boldon Business Park, Boldon Colliery, United Kingdom. NE35 9PE
FO-29 Revision 1 Tel: +44 (0)191 523 8877 4th June 2018