Introduction

Sarratt Office Supples needs to gather and use certain information about individuals of legitimate interest, (customers or prospective customers we have dealt with/communicated with in the past).

These can include customers, suppliers, business contacts, employees and other people 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 Sarratt Office Supplies:

▪ 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

Policy scope

This policy applies to the office of Sarratt Office Supplies, all its staff and customers. It applies to all data that the company holds relating to identifiable individuals,

including names of individuals, postal addresses, email addresses, telephone numbers and any other information relating to individuals.

Responsibilities

Everyone who works for or with Sarratt Office Suplies has some responsibility for ensuring data is collected, stored and handled appropriately in line with this policy and GDPR principles. However, areas of responsibility are assigned to a Data Protection Officer or other management as follows:

Area of responsibility Name

Reviewing all data protection procedures and related policies, in line with an agreed schedule Management
Arranging data protection training and advice for the people covered by this policy Management
Handling data protection questions from staff and anyone else covered by this policy Management
Dealing with requests from individuals to see the data Sarratt Office Supplies holds about them (also called ‘subject access requests’) Management
Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data Management
Ensuring all systems, services and equipment used for storing data meet acceptable security standards Management
Performing regular checks and scans to ensure security hardware and software is functioning properly Management
Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services Management
Approving communications and marketing initiatives meet data protection principles Management Management

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 manager.

▪ Sarratt Office Supplies 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.

▪ 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.

▪ When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

▪ 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.

▪ Servers containing personal data should be sited in a 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, a firewall and a password.

Data use

Personal data is of no value to Sarratt Office Supplies 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.

▪ 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. Always access and update the central copy of any data.

Data accuracy

The law requires Sarratt Office Supplies 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

Sarratt Office Supplies 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.

▪ Sarratt Office Supplies will make it easy for data subjects to update the information Sarratt Office Supplies 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.

Subject access requests

All individuals who are the subject of personal data held by Sarratt Office Supplies are entitled to:

▪ Ask what information the company holds about them, why, and for how long.

▪ 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. The data controller can supply a standard request form, although individuals do not have to use this. Individuals will not be charged for the request. The company 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, Sarratt Office Supplies will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.

Providing information

Sarratt Office Supplies 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 Statement is issued to all individuals for whom the company will hold data.