Data protection policy

Context and overview

Key details

  • Approved by board/management on: 25/05/2018
  • Policy became operational on: 25/05/2018
  • Next review date: 25/05/2019

Introduction

AWM Potatoes needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people that the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be 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 AWM Potatoes:

  • 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 individual’s data
  • Protects itself from the risk of a data breach

Data protection law

The Data Protection Act 1998 describes how organisations – including AWM Potatoes - 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, 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 to be transferred outside of the European Economic Area (EEA), unless that country or territory also ensures adequate level of protection.

Types of Information we hold, and how we use it

We hold information in our sage accounting software, company mobile phones, NatWest Bank and our company shared folder. The information is backed up daily. This information includes: -

  • Company Name
  • Company Address
  • Company buyer(s)/Sales/Accounts contacts as supplied
  • Various supplied Telephone and fax numbers
  • Various supplied email address
  • Account activities
  • Bank account details
  • Terms and conditions

How we use this information:

  • To manage your applications for our product.
  • To contact you for us to manage, administer and provide our product to you.
  • To communicate any updates to you including changes in terms and conditions of your finance agreement (if applicable) and any changes to our Privacy Policy.
  • To enable you to make payments for our product.
  • To enable us to make place orders and payments for services and supplies.
  • To make deliveries of our products (if applicable).
  • We may also use your personal information where it is necessary for us to take legal advice to establish our legal rights, to bring a claim against you or any related parties or to defend a claim from you or any related parties.

Note: We do not share this information with third parties, and we keep all invoices and credits onsite for 7 years.

 

This information is used to facilitate trading with your company.

 

People, risk and responsibilities

Policy scope

This policy applies to:

 

  • The head office of AWM Potatoes
  • All branches of AWM Potatoes
  • All staff and volunteers of AWM Potatoes
  • All contractors, suppliers and other people working on behalf of AWM Potatoes.

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:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • …plus, any other information relating to individuals

Data protection risk

This policy helps to protect AWM Potatoes 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.

Responsibilities

Everyone who works for or with AWM Potatoes has some responsibilities for ensuring data is collected, stored and handles appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas responsibility:

 

  • The board of directors is ultimately responsible for ensuring that AWM meets its legal obligations
  • The Accounts and HR Manager, Nick Franklin is responsible for:
    • Keeping the board updated about data protection responsibilities, risk 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 handling this policy.
    • Handling data protection questions from staff and anyone else covered by this policy.
    • Dealing with requests from individuals to see the data AWM Potatoes 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 Network and IT Service Provider, CSD 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.
  • The Managing Director, Andrew Morton is responsible for:
    • 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.

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.
  • AWM Potatoes 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 the data protection officer if they are unsure about any aspect of data protection.

Data storage

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.

When data is stored on paper, 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 the 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 sed.
  • Data should only be stored on designated drives and servers and should only 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 laptop 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.

Data use

Personal data is of no value to AWM Potatoes 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.

Data accuracy

The law requires AWM Potatoes 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 AWM Potatoes 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 data 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.

  • AWM Potatoes will make it easy for data subjects to update the information AWM Potatoes 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 sixth months.

Your data protection rights

You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so by contacting us using the contact details provided under the “how to contact us” heading bellow.
  • In addition, you can object to processing of your request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading bellow.
  • If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor

will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

  • You have the right to complain to a data protection authority about your collection and use of your personal information. For more information, please contact your local data protection authority.

Subject access request

All individuals who are the subject of personal data held by AWM Potatoes 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 called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at This email address is being protected from spambots. You need JavaScript enabled to view it.. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. 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.

Disclosing data for other reasons

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, AWM Potatoes will disclose requested data. However, the data controller will ensure the request s legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Updates to this Privacy Policy

We may change or update this Privacy Policy to maintain our compliance with applicable law and regulation or following an update to our internal practices. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

How to contact us

If you would like to contact us in relation to this Privacy Policy, or anything else in connection with the personal information we collect about you, please contact us using the details set out below:

Telephone: 01376 321200

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.