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1717

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Data Protection Policy & Procedures

Definition

Everyone has rights with regard to how their personal information is handled and stored. During the course of our activities we will collect, store and process personal information about our employees, customers, suppliers and other third parties. We recognise the need to treat it in an appropriate and lawful manner.

Any breach of this policy will be taken seriously and may result in disciplinary action.

The types of information that we may be required to handle include details of current, past and prospective employees, 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 Data Protection Act 1998 (The Act) and other regulations. The Act imposes restrictions on how the company may use that information. If an employee feels this policy has been breached in anyway then they should inform their manager.

Anyone processing personal data must comply with the eight enforceable principles of good practice set out in the Data Protection Act (DPA) 1998. These provide that personal data must be:

  • Processed fairly and lawfully.
  • Processed for limited purposes and in an appropriate way.
  • Adequate, relevant and not excessive for the purpose.
  • Accurate.
  • Not kept longer than necessary for the purpose.
  • Processed in line with data subjects' rights.
  • Secure.
  • Not transferred to people or organisations situated in countries without adequate protection.

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 David Hall), the purpose for which the data is to be processed, and the identities of anyone to whom the data may be disclosed or transferred.

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.

Data about employees may be processed for legal, personnel, administrative and management purposes and to enable the data controller to meet its legal obligations as an employer, for example to pay employees, monitor their performance and to confer benefits in connection with their employment. Examples of when sensitive personal data of employees is likely to be processed are set out below:

  • Information about an employee's physical or mental health or condition in order to monitor sick leave and take decisions as to the employee's fitness for work.
  • The employee's racial or ethnic origin or religious or similar information in order to monitor compliance with equal opportunities legislation.
  • In order to comply with legal requirements and obligations to third parties.
  • Data about customers, suppliers and other third parties may be processed for the following purposes.
  • Other third parties – to store information for partnerships and working relationships (existing and potential).

Processing for limited processes

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.

Adequate, relevant and non-excessive processing

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.

Accurate data

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.

Data retention

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. For guidance on how long certain data is likely to be kept before being destroyed, contact the head of it or the chief financial officer.

Processing in line with data subjects’ rights

Data will be processed in line with data subjects' rights. Data subjects have a right to:

  • Request access to any data held about them by a data controller.
  • Prevent the processing of their data for direct-marketing purposes.
  • Ask to have inaccurate data amended.
  • Prevent processing that is likely to cause unwarranted substantial damage or distress to themselves or anyone else.
  • Object to any decision that significantly affects them being taken solely by a computer or other automated process.

Data security

The Company 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.

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.

Maintaining data security means guaranteeing the confidentiality, integrity and availability of the personal data, defined as follows:

  • Confidentiality means that only people who are authorised to use the data can access it.
  • Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
  • 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.
  • Any data collected via the contact form on our website will be transferred to only our email address to which only staff have access too. No other source will receive this information.

Security procedures include:

  • Entry controls: any stranger seen in entry-controlled areas should be reported, any non-company employee is not to venture behind shop counter unless accompanied by a Morgan’s employee. All paperwork containing data to be stowed out of sight of any non-employee.
  • 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).
  • Methods of disposal: paper documents should be shredded. Disks should be physically destroyed when they are no longer required.
  • Equipment: data users should ensure that individual monitors do not show confidential information to passers-by and that they log off or lock their pc when it is left unattended.
  • Paperwork: no customer data left un-attended in public areas.

Any employee dealing with customer enquiries or information is required to adhere to the following:

  • Request information according to current policy.
  • Information must be stored directly into the relevant system, as close to the time of contact as possible. Paper record information must be stored according to our systems.

Any employee dealing with enquiries from third parties should be careful about disclosing any personal information held by us. In particular, they should:

  • Check the identity of the person making the enquiry and whether they are legally entitled to receive the information they have requested.
  • Suggest that the third party put their request in writing so the third party's identity and entitlement to the information may be verified.
  • Refer to the store manager/head of department for assistance in difficult situations.
  • Where providing information to a third party, do so in accordance with the eight data protection principles.