Dated: March 2018
Next Review: March 2020

Revision and Approval

RevDateNature of ChangeApproved ByIntegrity Checked
01March 2018Original IssueT. Cooper

1.0 Introduction

TC Carpentry Construction Ltd needs to gather and use certain information about individuals.

These can include customers, sub-contractors, suppliers, business contacts, employees and other people the company 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.

This data protection policy ensures TC Carpentry Construction Ltd:

  • Complies with data protection law and follow good practise
  • Protects the rights if staff, customers and partners
  • Is open about how it stores and processes individuals data
  • Protects itself from the risks of data breach

2.0 Data Protection Law

The Data Protection Act 1998 describes organisations – including TC Carpentry Contractors 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:

  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 right of data subjects
  7. Be protected in appropriate ways
  8. Not be transferred outside the Euroopean Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.

3.0 Policy Scope

This policy applies to:

  • TC Carpentry Contractors Ltd – Office
  • All staff, volunteers, sub-contractors, apprentices
  • All contractors, suppliers and other people working on behalf of TC Carpentry Contractors Ltd.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls out 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

4.0 Data Protection Risks

This policy helps to protect TC Carpentry Contractors Ltd from some very real data security risks, including:

  • Breaches of confidentiality. For instance, information being given pout inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the company use data relating to them.
  • Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

5.0 Responsibilities

Everyone who works for or with TC Carpentry Contractors Ltd has some responsibility for ensuring data is collected, stored and handled appropriately.

Anyone whom 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 of responsibility:

  • Managing Director, Toby Coper is ultimately responsible for ensuring that TC Carpentry Contractors Ltd meets its legal obligations.
  • The Data Protection Officer, Suzanne Peak is responsible for:
    • Keeping the Managing Director 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 advise for 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 TC Carpentry Contractors 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.

6.0 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.
  • TC Carpentry Contractors Ltd 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 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 the data protection officer if they are unsure about any aspect of data protection.

7.0 Data Storage

These rules describe how and where data should be safely stored. Question sabout storing data safely can be directed to the data controller.

When data is stored on paper, it should be kept in a secure place.

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 services such as Dropbox.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • All computers and laptops containing data should be protected by approved security software and a firewall.

8.0 Data Use

Personal data is of no value to TC Carpentry Contractors Ltd unless the business can make use of it. However, It is when personal data is accessed and used that is 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.
  • Personal data should never be transferred outside of the European Economic Area.
  • Employees should not save copies of personal data to their own computers.

9.0 Data Accuracy

The law requires TC Carpentry Contractors Ltd to take responsible 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 TC Carpentry Contractors Ltd 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 paces as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For example updating contracts contact details.

10.0 Subject Access Requests

All individuals who are the subject of personal data held by TC Carpentry Contractors Ltd 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.

The data controller will verify the identity of anyone making a subject access request before handing over any information.

11.0 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, TC Carpentry Contractors Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the Managing Director and from the company’s legal advisers where necessary.

12.0 Providing Information

TC Carpentry Contractors 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.

Please note: The Original document, signed, dated and subject to regular review will be held in the head office.