Fitted Your Way Ltd shall comply with the principles of data protection (the Principles) enumerated in the EU General Data Protection Regulation.
The only data we collect and process includes: First name, surname, title, gender, company position/job title, company email address, company name, company telephone number and company address.
We will make every effort possible in everything we do to comply with these principles. The Principles are:
Lawful, fair and transparent
Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.
Limited for its purpose
Data can only be collected for a specific purpose.
Any data collected must be necessary and not excessive for its purpose.
The data we hold must be accurate and kept up to date.
We cannot store data longer than necessary.
Integrity and confidentiality
The data we hold must be kept safe and secure.
Fitted Your Way Ltd is committed to protecting the rights and freedoms of data subjects and safely and securely processing their data in accordance with all of our legal obligations.
We hold personal data about our employees, clients, suppliers and other individuals for a variety of business purposes.
This policy sets out how we seek to protect personal data and ensure that our staff understand the rules governing their use of the personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.
|Business purposes||The purposes for which personal data may be used by us: Personnel, administrative, financial, regulatory, payroll and business development purposes. Business purposes include the following:– Compliance with our legal, regulatory and corporate governance obligations and good practice– Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests– Ensuring business policies are adhered to (such as policies covering email and internet use)– Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking– Investigating complaints– Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments– Monitoring staff conduct, disciplinary matters– Marketing our business– Improving services|
|Personal data||‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an 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.Personal data we gather may include: individuals’ phone number, email address, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.|
|Special categories of personal data||Special categories of data include information about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings, and genetic and biometric information —any use of special categories of personal data should be strictly controlled in accordance with this policy.|
|Data controller||‘Data controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law.|
|Data processor||‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.|
|Processing||‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.|
|Supervisory authority||This is the national body responsible for data protection. The supervisory authority for our organisation is [the Information Commissioners Office].|
This policy applies to all staff, who must be familiar with this policy and comply with its terms.
This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.
Who is responsible for this policy?
As our data protection officer (DPO), [Matt Jordan] has overall responsibility for the day-to-day implementation of this policy. You should contact the DPO for further information about this policy if necessary.
Director, Fitted Your Way Ltd
Fitted Your Way Ltd is classified as a data controller and data processor. We must maintain our appropriate registration with the Information Commissioners Office in order to continue lawfully controlling and processing data.
We must establish a lawful basis for processing data. Ensure that any data you are responsible for managing has a written lawful basis approved by the DPO. It is your responsibility to check the lawful basis for any data you are working with and ensure all of your actions comply the lawful basis. At least one of the following conditions must apply whenever we process personal data:
We hold recent, clear, explicit, and defined consent for the individual’s data to be processed for a specific purpose.
The processing is necessary to fulfil or prepare a contract for the individual.
- Legal obligation
We have a legal obligation to process the data (excluding a contract).
- Vital interests
Processing the data is necessary to protect a person’s life or in a medical situation.
- Public function
Processing necessary to carry out a public function, a task of public interest or the function has a clear basis in law.
- Legitimate interest
The processing is necessary for our legitimate interests. This condition does not apply if there is a good reason to protect the individual’s personal data which overrides the legitimate interest.
How we collect and process data
Fitted Your Way Ltd ensures all collection of personal data is of an ethical and legal manner, and can be from (not limited to) the following sources:
- Website contact form
- Email enquiry
- Telephone enquiry
- Social media engagement
- Postal enquiry
Any information you pass to us via the above methods will be used solely for the purpose it was intended, and will not be used for any other purpose without your consent.
- Analysing and documenting the type of personal data we hold
- Checking procedures to ensure they cover all the rights of the individual
- Identify the lawful basis for processing data
- Ensuring consent procedures are lawful
- Implementing and reviewing procedures to detect, report and investigate personal data breaches
- Store data in safe and secure ways
- Assess the risk that could be posed to individual rights and freedoms should data be compromised
- Fully understand your data protection obligations
- Check that any data processing activities you are dealing with comply with our policy and are justified
- Do not use data in any unlawful way
- Do not store data incorrectly, be careless with it or otherwise cause us to breach data protection laws and our policies through your actions
- Comply with this policy at all times
- Raise any concerns, notify any breaches or errors, and report anything suspicious or contradictory to this policy or our legal obligations without delay
Responsibilities of the Data Protection Officer
- Keeping the board updated about data protection responsibilities, risks and issues
- Reviewing all data protection procedures and policies on a regular basis
- Arranging data protection training and advice for all staff members and those included in this policy
- Answering questions on data protection from staff, board members and other stakeholders
- Responding to individuals such as clients and employees who wish to know which data is being held on them by us
Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing.
Accuracy and relevance
We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO.
You must keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
Individuals have rights to their data which we must respect and comply with to the best of our ability. We must ensure individuals can exercise their rights in the following ways:
- Right to be informed
- Providing privacy notices which are concise, transparent, intelligible and easily accessible, free of charge, that are written in clear and plain language, particularly if aimed at children.
- Keeping a record of how we use personal data to demonstrate compliance with the need for accountability and transparency.
- Right of access
- Enabling individuals to access their personal data and supplementary information
- Allowing individuals to be aware of and verify the lawfulness of the processing activities
- Right to rectification
- We must rectify or amend the personal data of the individual if requested because it is inaccurate or incomplete.
- This must be done without delay, and no later than one month. This can be extended to two months with permission from the DPO.
- Right to erasure
- We must delete or remove an individual’s data if requested and there is no compelling reason for its continued processing.
- Right to restrict processing
- We must comply with any request to restrict, block, or otherwise suppress the processing of personal data.
- We are permitted to store personal data if it has been restricted, but not process it further. We must retain enough data to ensure the right to restriction is respected in the future.
- Right to data portability
- We must provide individuals with their data so that they can reuse it for their own purposes or across different services.
- We must provide it in a commonly used, machine-readable format, and send it directly to another controller if requested.
- Right to object
- We must respect the right of an individual to object to data processing based on legitimate interest or the performance of a public interest task.
- We must respect the right of an individual to object to direct marketing, including profiling.
- We must respect the right of an individual to object to processing their data for scientific and historical research and statistics.
- Rights in relation to automated decision making and profiling
- We must respect the rights of individuals in relation to automated decision making and profiling.
Individuals retain their right to object to such automated processing, have the rationale explained to them, and request human intervention.
How to perform a subject access request?
Subject access requests from individuals should be made by email and address to the data controller (Matt Jordan) at firstname.lastname@example.org. The data controller can supply a standard request form, and will aim to provide such information within 14 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
Fitted Your Way 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
Disclosing 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, Fitted Your Way 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.
Policy prepared by: Matt Jordan
Approved by board on: 1st September 2019
Policy became operational on: 1stSeptember
Next review date: 1stSeptember 2020