B-Line Group (including but not limiting to, B-Line Ltd, B-Line Recruitment, B-Line Training, Green and Construction Ltd) 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 will be collected, handled and stored to meet the company’s data protection standards — and to comply with General Data Protection Regulations(GDPR) 2018.
Why this policy exists
This data protection policy ensures B-Line:
· Complies with data protection law and follow good practice
· Protects the rights of staff, client, customers and partners
· 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 and the General Data Protection Regulations 2016 describe how organisations — including B-Line Group will 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 will be collected and processed fairly, stored safely and not disclosed unlawfully.
The Data Protection Act is underpinned by eight important principles. These say that personal data will:
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 theEuropean Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, risks and responsibilities
This policy applies to:
· The head office of B-Line
· All branches of B-Line
· All staff and volunteers ofB-Line
· All contractors, suppliers and other people working on behalf of B-Line
It applies to all data that the company holds relating to identifiable individuals, even that information technically falls outside of the Data Protection Act 1998 or GDPR 2016. 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 B-Line from some very real data security risks,
· Breaches of confidentiality. For instance, information being given out inappropriately.
· Failing to offer choice. For instance, all individuals will 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 B-Line has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data will 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 Managing Director is ultimately responsible for ensuring that B-Line meets its legal obligations.
· The Data Protection Officer, is responsible for:
o Keeping the board updated about data protection responsibilities, risks and issues.
o Reviewing all data protection procedures and related policies, in line with an agreed schedule.
o Arranging data protection training and advice for the people covered by this policy.
o Handling data protection questions from staff and anyone else covered by this policy.
o Dealing with requests from individuals to see the data B-Line holds about them (also called ‘subject access requests’).
o Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
· The IT manager, is responsible for:
o Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
o Performing regular checks and scans to ensure security hardware and software is functioning properly.
o Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
· The marketing manager, is responsible for:
o Approving any data protection statements attached to communications such as emails and letters.
o Addressing any data protection queries from journalists or media outlets like newspapers.
o 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 will be those who need it for their work.
· Data will not be shared informally. When access to confidential information is required, employees can request it from their line managers.
· B-Line will provide training to all employees to help them understand their responsibilities when handling data.
· Employees will keep all data secure, by taking sensible precautions and following the guidelines below.
· In particular, strong passwords will be used and they will never be shared.
· Personal data will not be disclosed to unauthorised people, either within the company or externally.
· Data will be regularly reviewed and updated if it is found to be out of date. If no longer required, it will be deleted and disposed of.
· Employees will request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
These rules describe how and where data will 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 will 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 will be kept in a locked drawer or filing cabinet.
· Employees will make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
· Data printouts will be shredded and disposed of securely when no longer required.
· When data is stored electronically, it will be protected from unauthorised access, accidental deletion and malicious hacking attempts:
· Data will 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 will be kept locked away securely when not being used.
· Data will only be stored on designated drives and servers, and will only be uploaded to an approved cloud computing services.
· Servers containing personal data will be sited in a secure location, away from general office space.
· Data will be backed up frequently. Those backups will be tested regularly, in line with the company’s standard backup procedures.
· Data will never be saved directly to laptops or other mobile devices like tablets or smart phones.
· All servers and computers containing data will be protected by approved security software and a firewall.
B-Line collects and uses your personal information to help deliver the services you have requested. B-Line may use your information for marketing purposes and may contact you by mail, telephone, fax, e-mail or other electronic messaging service to inform you of offers of goods and services or information that may be of interest to you about our services, materials, news or training. B-Line may also contact you via surveys to conduct research about your opinion of current services or of potential new services on offer. When you provide us with your fax number, telephone numbers or email address you consent to being contacted by these methods for these purposes. If you do not wish to receive such information from us, please contact firstname.lastname@example.org at any time. No further action is necessary if you have previously indicated to us that you do not want to receive such marketing material. B-Line will only hold your personal data for as long as is reasonable necessary.
If you are our client your continuing relationship with us demonstrates your consent to this processing. We do not disclose sensitive personal information such as race, religion, or political afflictions, without your explicit consent. Also, the data will not be transferred or stored in any overseas country other than the UK for our business.
When you give us information about another individual for business purposes, you do so on the basis that the other individual has agreed and has consented to the processing of his or her personal data, including sensitive data, and to the transfer of his or her information abroad and to your receiving on his or her behalf any data protection notices.
Personal data is of no value to B-Line 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 will ensure the screens of their computers are always locked when left unattended.
· Personal data will not be shared informally. In particular, it will never be sent by email, as this form of communication is not secure.
· Data will be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
· Personal data will never be transferred outside of the European Economic Area.
· Employees will not save copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires B-Line 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 B-Line will 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 will not create any unnecessary additional datasets.
· Staff will take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
· B-Line will make it easy for data subjects to update the information B-Line holds about them. For instance, via the company website.
· Data will be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it will be removed from the database.
· It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject access requests
All individuals who are the subject of personal data held by B-Line 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 will 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.
Each subject access request will be processed and provided completely free of charge to all individuals. 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 reasons
In certain circumstances, the Data Protection Act 1998 allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, B-Line 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.
B-Line 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 is available on request. A version of this statement is also available on the company’s website. This policy is to be reviewed at least once annually]