Here we aim to let you know exactly what we do and do not use your personal information for. This includes use of third parties, security and data breach situations.
Company: means Jacqueline Summer
GDPR: means 'General Data Protection Regulation'.
Responsible Person / Data Protection Officer: means Jacqueline Summer .
Register of Systems: means a register of all systems or contexts in which personal data is processed by the Company.
1. Data protection principles
The Company is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that 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 and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
5. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General provisions
1. This policy applies to all personal data processed by the Company.
2. The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
3. This policy shall be reviewed at least annually.
4. The Company shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
1. To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
2. The Register of Systems shall be reviewed at least annually.
3. Individuals have the right to access their personal data and any such requests made to the Company shall be dealt with in a timely manner, usually within one month from the date of receiving the request.
4. Lawful purposes
1. All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
2. The Company shall note the appropriate lawful basis in the Register of Systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.
5. Data minimisation
1. The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
2. Where personnel of the Company carry out work that involves a third party, such as but not limited to: provision of outside specialist goods and/or services, design of a marketing leaflet, book or other item(s) which require printed contact details of more than one person/business and associated third party printing of sensitive contact details, the Company will ensure that a minimal amount of data is passed to the third party, only when the Company has sought the client's individual consent.
3. The client has a right to view and/or obtain any such printed design material in which they feature.
4. Due to the nature of some print-runs, some client details and/or third party data may be made public and the Company will not be held liable for loss, damages or claims made by or against the client or third party, once the printed format is circulated in the public arena.
5. From time to time it may be necessary to ask the client to have direct contact with a third party service provider, in which case it will be the client's responsibility to provide appropriate information, be it full name, email address, date of birth, payment details etc. The client will be responsible for updating and maintaining details kept on file by the third party provider.
1. The Company shall take reasonable steps to ensure personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
3. The Company shall do it's utmost to keep the most up-to-date and relevant data on file, however, where a client has failed to make a payment or moved without notifying the Company of their change of details, the Company will seek to update relevant data through legal search channels and in the eventuality of the client being deceased, Company measures will be followed to ensure data are irrecoverably deleted from files, unless required to follow up on debts outstanding to the Company. Once satisfied, the data will be deleted permanently from the Company's register after 6 years.
7. Archiving / removal
1. To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
2. The archiving policy shall consider what data should/must be retained, for how long, and why.
3. Your rights to adjust, omit, update, remove and/or transfer data are important to us, please email with your request of data removal. (see 7.4)
4. We will not be held liable for personal or business losses, should you furnish us with wrong information/data or forcefully seek to remove your data from our files, if it is required for purposes of ongoing maintenance of an account we hold on your behalf, including but not limited to long term practical work or website hosting/design.
1. The Company shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
2. In some cases it may be a requirement of the Company to store data off-site or in printed form. Data will remain in a locked, secured environment. Only Company personnel shall have access if required for the purposes of business with the owner of the data.
3. Where legally permitted third parties, such as an officially checked representative of the UK police, HMRC or other appropriate governing body seek access, a company representative will duly seek to inform the client(s) of this action as soon as possible. The Company cannot be held responsible for loss or damages if files/data are removed from business premises and taken away by such third parties, for legal examination and/or research purposes..
4. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information, with the exception of 8.3 above.
5. When personal data is deleted this should be done safely in such a way that the data is irrecoverable.
6. Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
END OF POLICY