Meltog Limited – Data Protection Policy Statement
Meltog Ltd needs to gather and use certain information about individuals. These includes 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 is 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 Meltog Ltd:
* Complies with data protection law and follow good practice
* Protects the right 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:
The General Data Protection Regulation (GDPR) describes how organisations, including Meltog Ltd, must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, any personal information that Meltog collects is used fairly, stored safely and not disclosed unlawfully.
People, risks and responsibilities
This policy applies to:
* The head office of Meltog Ltd
* All branches of Meltog Ltd
* All staff and volunteers of Meltog Ltd
* All contractors, suppliers and other people working on behalf of Meltog Ltd
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the General Data Protection Regulation. This can include:
* Names of individuals
* Postal addresses
* Email addresses
* Telephone numbers
* Plus any other information relating to individuals
Data protection risks:
This policy helps to protect Meltog Ltd 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.
Everyone who works for or with Meltog Ltd has one responsibility for ensuring data is collected, stored and handled appropriately. Each team that handles personal data ensures that it is handled and processed in line with this policy and data protection principles.
However, these people have key areas of responsibility:
* The board of directors is ultimately responsible for ensuring that Meltog Ltd meets its legal obligations.
* The company’s Data protection officer, Brian Manson, is responsible for:
* 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 Meltog 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
* The IT Manager, Darren Ellis, is 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
* Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services
* Any persons engaging in marketing activity will:
* Seek approval for any data protection statements attached to communications such as emails and letters
* Address any data protection queries from journalists or media outlets like newspapers
* Where necessary, working with other staff, ensure marketing initiatives abide by data protection principles
General staff 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. When access to confidential information is required, employees can request it from their line managers
* Meltog Ltd 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 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 the data protection officer if they are unsure about any aspect of data protection
These rules describe how and where data is safely stored by the company. Any questions about storing data safely can be directed to the IT manager or data controller.
When data is stored on paper, it is kept in a secure place where unauthorised people cannot see it or access 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 are kept in a locked drawer or filing cabinet
* Employees will ensure paper and printouts are not left where unauthorised people could see them, for example on a printer
* Data printouts will be shredded and disposed of securely when no longer required
Where data is stored electronically, it is protected from unauthorised access, accidental deletion and malicious hacking attempts:
* Such data is protected by strong passwords that are changed regularly and never shared between employees
* If data is stored on removeable media (like a CD or DVD), these are kept locked away securely when not being used
* Data is only be stored on designated drives and servers, and is uploaded to an approved cloud computing service, when required
* Servers containing personal data are sited in a secure location, away from general office space
* Data is backed up frequently. Backups should be tested regularly, in line with the company’s standard backup procedures
* Data is never be saved directly to laptops or other mobile devices like tablets or smart phones
* All servers and computers containing data are protected by approved security software and a firewall
Personal data is of no value to Meltog Ltd unless the business can make use of it:
* When working with personal data, employees will ensure the screens of their computers are always locked when left unattended
* Personal data is not be shared informally.
* Data is encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts
* Personal data will 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
The law requires Meltog Ltd to take reasonable steps to ensure data is kept accurate and up to date, through regular review and audit, the company ensures this happens.
Any company employee that works with personal data will take all reasonable steps to ensure it is kept as accurate and up to date as possible.
* Data is held in as few places as necessary. Staff will not create any unnecessary additional data sets
* Staff will take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call
* Meltog Ltd will make it easy for data subjects to update the information Meltog Ltd holds about them. For instance, via the company website
* Data will 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
Subject access requests
All individuals who are the subject of personal data held by Meltog 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 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 controller at <a href=”mailto:firstname.lastname@example.org”>email@example.com</a>. The data controller can supply a standard request form, although individuals do not have to use this.
The data controller will aim to provide the relevant data within 30 days.
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 General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Meltog Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Meltog Ltd 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 statement, setting out how data relating to individuals is used by the company.
[This is available on request. A version of this statement is also available on the company’s website.]