Data Protection Policy
Context and Overview
Policy prepared by: Paul Gibbs-Murray
Approved by management on: 21st May 2018
Policy became operational on: 21st May 2018
Next review date: 20th May 2019
Hawthorn Accountancy Solutions Ltd needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact
Why this policy exists
This data protection policy ensures Hawthorn Accountancy Solutions Ltd:
- 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 individuals’ data Protects itself from the risks of a data breach
Data protection law
The Data Protection Act 1998 describes how organisations — including Hawthorn Accountancy Solutions 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, 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:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection People, risks and responsibilities
This policy applies to:
- The officers of Hawthorn Accountancy Solutions Ltd
- All staff and volunteers of Hawthorn Accountancy Solutions Ltd
- All contractors, suppliers and other people working on behalf of Hawthorn Accountancy Solutions Ltd.
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 risks
This policy helps to protect Hawthorn Accountancy Solutions 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 Hawthorn Accountancy Solutions Ltd has some responsibility for ensuring data is collected, stored and handled appropriately.
All employees/authorised personnel have signed a confidentiality clause in their contract of employment.
Each employee 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 Hawthorn Accountancy Solutions Ltd meets its legal obligations.
The GDPR Officer, Paul Gibbs-Murray 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 Hawthorn Accountancy Solutions 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.
- 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.
- 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 will be those who need it for their work.
Data will not be shared informally. All confidential data is available to authorised personnel via password protected databases.
Hawthorn Accountancy Solutions Ltd will provide training to all employees to help them understand their responsibilities when handling data.
Employees keep all data secure, by taking sensible precautions and following the guidelines below.
Passwords are used to access software and in certain cases documentation and they are only ever shared with authorised personnel.
Personal data is not disclosed to unauthorised people, either within the company or externally.
Data is regularly reviewed and updated if it is found to be out of date. If no longer required, it is deleted and disposed of by using licensed confidential waste carriers.
Employees can request help from their line manager or the GDPR officer if they are unsure about any aspect of data protection.
The following rules describe how and where data is stored. Questions about storing data safely can be directed to the data controller.
When data is stored on paper, it is kept in a secure place where unauthorised people cannot see it.
The guidelines below 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 stored in the company office which is protected by two locked access doors and a security alarm. The building/offices can only be accessed by authorised personnel.
- Employees make sure paper and printouts are not left where unauthorised people could see them.
- Data printouts are disposed of securely when no longer required via a licensed waste disposal company who provide Hawthorn Accountancy Solutions Ltd with sealable confidential waste bags for collection and a certificate of secure disposal.
When data is stored electronically, it will be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data is protected by strong passwords.
- Data is only stored on designated drives and servers and is only uploaded to an approved cloud computing service.
- Servers containing personal data are sited in a secure location, away from general office space. These may belong to the software providers e.g. Yoli, Workflowmax, Sage, Orbits etc. and are in different locations based depending on their owner/operators Data is backed up frequently.
- Data is only saved to company owned/authorised devices such as laptops or other mobile devices.
- All servers and computers containing data are protected by approved security software and a firewall.
Personal data is of no value to Hawthorn Accountancy Solutions Ltd 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:
- Personal data should not be shared informally. Any documents sent via email are protected by a password which is sent separately to the recipient.
- Personal data is never transferred outside of the European Economic Area.
- Employees do not save copies of personal data to their own computers. They always access and update the central copy of any data.
The law requires Hawthorn Accountancy Solutions Ltd 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 Hawthorn Accountancy Solutions Ltd will 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 is held in as few places as necessary. Staff do not create any unnecessary additional data sets.
- Staff take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
- Hawthorn Accountancy Solutions Ltd will make it easy for data subjects to update the information Hawthorn Accountancy Solutions Ltd holds about them.
- Data is updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it will be removed/updated in the database.
Subject access requests
All individuals who are the subject of personal data held by Hawthorn Accountancy Solutions Ltd are entitled to:
- Ask what information Hawthorn Accountancy holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how Hawthorn Accountancy 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 firstname.lastname@example.org . 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, Hawthorn Accountancy Solutions Ltd will disclose requested data. However, the data controller will always ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Hawthorn Accountancy Solutions 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.]