Policies

Data Protection Policy

Introduction

Abbot Fixings Systems Limited needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and others with whom the organisation has a relationship or may need to contact. This policy details how this personal data must be collected, managed and stored in order to meet the company’s data protection standards and to comply with the law. The policy has been reviewed in line with the GDPR (General Data Protection Regulation) which came into effect in April 2016.

This data protection policy ensures Abbot Fixings Systems Limited:

  • Complies with data protection law and follows good practice;
  • Protects the rights of staff, customers and partners;
  • Is open about how it stores and processes data;
  • Protects itself from the risks of a data breach;

The Data Protection Act 1998 describes how organisations, including Abbot Fixings Systems Limited, must collect, handle and store personal information. The GDPR expands on some areas of this Act. 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:

  1. Be processed fairly and lawfully;
  2. Be obtained only for specific, lawful purposes;
  3. Be adequate, relevant and not excessive;
  4. Be accurate and kept up to date;
  5. Not be held for any longer than necessary;
  6. Processed in accordance with the rights of data subjects;
  7. Be protected in appropriate ways;
  8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection;

The Company is committed to uphold the key elements of GDPR in relation to the following defined areas;

  • Personal data’ is defined as ‘any information relating to an identified or identifiable person: an identifiable person is one who is identified directly or indirectly, in particular by reference to an identifier such as a name, and identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person’. This means that any online data could be combined with other data that can be used to identify a person;
  • The extension of ‘Special Categories’ – what was previously called ‘Sensitive Personal Data’;
  • Raising ‘Consent’ to a new status – explicit rather than generic, specifically to opt-in rather than ‘implied consent’. GDPR uses expressions such as ‘clear affirmative action’;
  • Extending the right of individuals to know what data is held on them ‘Subject Access Requests’;
  • Introducing the need to report all breaches and also keep accurate records;

Policy scope. This policy applies to:

  • The head office of Abbot Fixings Systems Limited;
  • All branches of Abbot Fixings Systems Limited;
  • All staff and volunteers of Abbot Fixings Systems Limited;
  • All contractors, suppliers and other people working on behalf of Abbot Fixings Systems Limited;

It applies to all data that the company holds relating to identifiable individuals. This can include:

• Names of individuals;
• Postal addresses;
• Email addresses;
• Telephone numbers
• Plus any other information relating to individuals;

This policy helps to protect Abbot Fixings Systems Limited 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 Abbot Fixings Systems Limited has some responsibility for ensuring data is collected, stored and handled appropriately. This includes ensuring that the reason the data is collected is legitimate and that consent has been obtained for the collection, use and storage of data.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles. However, the following people have key areas of responsibility:

The board of directors is ultimately responsible for ensuring that Abbot Fixings Systems Limited meets its legal obligations.

The data protection officer, Kevin Wooding, 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 Abbot Fixings Systems Limited 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, Anton Hinxman, 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 are functioning properly.
  • Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

The managing director, Richard Goonetilleke, is responsible for:

  • Approving any data protection statements attached to communications such as emails and letters.
  • Ensuring data held is accurate and that consent has been obtained for marketing purposes.
  • 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.

  • 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 management.
  • Abbot Fixings Systems Limited 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 securely.
  • 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 should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

Where unauthorised people do not have access to 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 not required, the paper or files should be kept in a locked drawer or filing 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.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • 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 only be uploaded to an approved cloud computing service.
  • 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 a firewall.

Personal data is of no value to Abbot Fixings Systems Limited 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:

  • 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 to 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.

The law requires Abbot Fixings Systems Limited to take reasonable 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 Abbot Fixings Systems Limited should put into ensuring its accuracy. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance by confirming a customer’s details when they call.
  • Abbot Fixings Systems Limited will make it easy for data subjects to update the information the company 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.

Abbot Fixings Systems Limited undertakes to keep and update records regarding data held and consent obtained. It will be transparent regarding what consent is being given to and will aim for full transparency. It will accurately record when consent was given and to whom. It will undertake not to disadvantage anyone not giving consent. It will provide the capability to opt-out at any point. It will record that consent was withdrawn and the action taken.

Reporting breaches is now a requirement and this must be done within 72 hours of the breach being discovered. The company will notify the individual concerned if the risk is high

All individuals who are the subject of personal data held by Abbot Fixings Systems Limited 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 richardabbfix@btconnect.com The data controller can supply a standard request form, although individuals do not have to use this.

There will be no charge made for subject access requests. The data controller will aim to provide the relevant data within 14 days. The data controller will always verify the identity of anyone making a subject access request before handing over any information.

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Abbot Fixings Systems Limited will disclose the 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.

01908 511730

sales@abbotfixings.com

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