Context and overview
- Policy prepared by: 20th April 2018
- Approved by directors on: 20th April 2018
- The policy became operational on: 20th April 2018
- Next review date: 20th April 2019
Petersfield Tutors 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.
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 Petersfield Tutors:
- Complies with data protection law and follow good practice
- Protects the rights of customers and tutors
- 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 Petersfield Tutors— 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:
- All people working on behalf of Petersfield Tutors.
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 Petersfield Tutors from some very real data security risks, including:
- Breaches of confidentiality. For instance, the 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 Petersfield Tutors has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team 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:
- The directors are ultimately responsible for ensuring that Petersfield Tutors meets its legal obligations.
- The data protection officer, Ganit Lev-Morgan, is responsible for:
- Keeping the team 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 tutors and anyone else covered by this policy.
- Dealing with requests from individuals to see the data Petersfield Tutors 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.
- The IT manager, Ganit Lev- Morgan, is responsible for:
- 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.
- The marketing manager, Ganit Lev-Morgan, is responsible for:
- 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 should be those who need it for their work.
- Data should not be shared informally. When access to confidential information is required, tutors can request it from the directors.
- Petersfield Tutors will provide training to all tutors to help them understand their responsibilities when handling data.
- Tutors 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 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.
Tutors should request help from the directors or the data protection officer if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
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.
- Tutors 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 among 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 approved cloud computing services.
- Servers containing personal data should be sited in a secure 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.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Petersfield Tutors 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.
- Personal data should never be transferred outside of the European Economic Area.
The law requires Petersfield Tutors 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 Petersfield Tutors should put into ensuring its accuracy.
It is the responsibility of all tutors 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. Tutors should not create any unnecessary additional data sets.
- Tutors should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
- Petersfield Tutors will make it easy for data subjects to update the information Petersfield Tutors 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 Petersfield Tutors 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 of how the company is meeting its data protection obligations.
If an individual makes contact with 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 email@example.com. The data controller can supply a standard request form, although individuals do not have to use this.
Individuals will be charged £10 per subject access request. 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 reason
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, Petersfield Tutors 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.
Petersfield Tutors 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
Petersfield Tutors abides by the European General Data Protection Laws (GDPR) and will never share your information with anyone outside the agency or via social media. We will pass your details on to our tutors when we have identified a suitable tutor to meet your requirements. We do not send unsolicited emails and will only contact you to send invoices or to discuss your personal needs.
Breaches in data security will be reported immediately to data protection authorities such as the Information Commissioner’s Office (ICO) in the UK. Ideally, breaches should be reported within 24 hours if possible but at least within 72 hours.
You have the right to be forgotten, to do so please contact us and we will delete all information we hold about you. You also have the right to request a copy of any information we hold about you, this may attract a small administrative fee. We will not hold your data if it is no longer required.