Malkin Photography
Helen Shelmerdine - Photographer and Author.
01434 381834 / 07733 010915
Middle Lee, Garrigill, Cumbria CA9 3HF, England
Data Protection & Privacy Policy Statement
Introduction
R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders need to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people they have a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored to meet the required data protection standards and to comply with the law.
Why this policy exists
This data protection policy ensures R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders:
*Comply with data protection law and follow good practice
*Protect the rights of staff and customers
*Are open about how they store and processes individuals' data
*Protect themselves from the risks of a data breach
Data protection law
The Data Protection Act (DPA), The Privacy and Electronic Communications Regulations (PECR) and
The General Data Protection Regulation (GDPR) describe how organisations, including R G SHELMERDINE & H M SHELMERDINE VARIOUSLY TRADING AS SOLE TRADERS, must collect, handle, use 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 be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
Policy scope
This policy applies to:
*The office of R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders
*All staff and volunteers of R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders
*All contractors, suppliers and other people working on behalf of R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders
It applies to all data that they hold relating to identifiable individuals, even if that information technically falls outside of The Data Protection Act (DPA), The Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulation (GDPR). This can include:
*Names of individuals
*Postal addresses
*Email addresses
*Telephone numbers
*Any other information relating to individuals
Data protection risks
This policy helps to protect R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders 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 R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders has some responsibility for ensuring data is collected, stored and handled appropriately.
Anybody 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 of responsibility:
R Shelmerdine & H Shelmerdine are ultimately responsible for ensuring that R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders meet their legal obligations. R Shelmerdine is the Data Protection Officer
The Data Protection Officer is responsible for:
* Keeping us 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 R G Shelmerdine & H M Shelmerdine variously Trading as Sole Traders
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.
*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 R G
Shelmerdine & H M Shelmerdine variously trading as Sole Traders.
*R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders 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 businesses or externally.
*Data should be regularly reviewed 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 R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders 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 Data Protection Officer.
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.
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 the Office PCs, and should only be uploaded to approved cloud computing services.
*Data should be backed up frequently, those backups should be tested regularly.
Data use
Personal data is of no value to R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders 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 Data Protection Officer 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 R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders to take reasonable steps to ensure data is kept accurate and up to date.
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.
*R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders will make it easy for data subjects to update the information
they hold about them.
*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 any database.
All individuals who are the subject of personal data held by R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders are entitled to;
*Ask what information they hold about them and why.
*Ask how to gain access to it.
*Be informed how to keep it up to date.
*Be informed how they are meeting their data protection obligations.
Subject Access Requests
If an individual contacts the business requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the bob@bobshelmerdine.co.uk. The Data Protection Officer can supply a standard request form, although individuals do not have to use this.
The Data Protection Officer will aim to provide the relevant data within 7 days.
The Data Protection Officer will always verify the identity of anyone making a subject access request before handing over any information.
In certain circumstances, The Data Protection Act (DPA), The Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulation (GDPR) allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders will disclose requested data. However, the Data Protection Officer will ensure the request is legitimate.
R G Shelmerdine & H M Shelmerdine variously trading as Sole Traders aim 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, this privacy statement and policy, sets out how data relating to individuals is used by them.