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GDPR

Seascape Photographer

 

Data Protection Policy

 

 

Context and Overview

 

Key details

 

  • Policy prepared by:                                                  Roy Fraser
  • Approved by board/management on:                      1 March 2018
  • Policy will become operational:                               25 May 2018
  • Next review date                                                          January 2019

 

Introduction

 

Seascape Photographer 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 Seascape Photographer:

  • 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

Data Protection Law

 

The Data Protection Act 1998 describes how organisations - including Seascape Photographer 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 principals.  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

People, risks and responsibilities

Policy Scope

This policy applies to:

  • The office of Seascape Photographer
  • All staff of Seascape Photographer
  • All contractors, suppliers and other people working on behalf of Seascape Photographer

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 number

Data protection risks

This policy helps to protect Seascape Photographer 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 Seascape Photographer has some responsibility for ensuring data is collected, stored and handled appropriately.

Each member of staff 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:

  • Roy Fraser is ultimately responsible for ensuring that Seascape Photographer meets its legal obligations.
  • The data protection officer, Roy Fraser is responsible for:

            ο          Keeping updated about data protection responsibilities,  risks and issues

            ο          Reviewing all data protection procedures  and related policies, in

                        line with an agreed schedule

            ο          Arranging data protection training and advice for the people

                        covered by this policy

            ο          Handling data protection questions from staff and anyone else

                        covered by this policy

            ο          Dealing with requests from individuals to see the data Seascape photographer holds about them (also called 'subject                              access requests').

            ο          Checking and approving any contracts or agreements with third

                        parties that may handle the company's sensitive data.

 

  • The IT officer, Roy Fraser is responsible for:

            ο          Ensuring all systems, services and equipment used for storing data

                        meet acceptable security standards.

            ο          Performing regular checks and scans to ensure security hardware

                        and software is functioning properly.

            ο          Evaluating any third-party services the company is considering

                        using to store or process data.  For instance, cloud computing

                        services.

  • Roy Fraser is responsible for:

            ο          Approving any data protection statements attached to

                        communications such as emails and letters.

            ο          Addressing any data protection queries from journalists or media

                        outlets like newspapers.

            ο          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, employees can request it from Roy Fraser.
  • Seascape Photographer 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 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 Roy Fraser 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 Roy Fraser.

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, 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, DVD or portable hard drive), 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 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.
  • Data should never be saved directly to mobile devices like tablets or smart phones.  Any data saved to laptops is in encrypted form.
  • All servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to Seascape Photographer 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.  This does not apply to photo images to which all staff have access at the office premises.
  • 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.  Roy Fraser 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 Seascape Photographer 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 Seascape Photographer 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.
  • Seascape Photographer will make it easy for data subjects to update the information Seascape Photographer 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 Seascape Photographer 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 it's 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, addressed to the data controller at  royfraser@btconnect.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 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, Seascape Photographer, 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.

Providing information

Seascape Photographer 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]

 

Seascape Photographer

Privacy Policy

 

At Seascape Photographer, we are committed to protecting and respecting your privacy.

This Policy explains when and why we collect personal information about people, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

Who are we?

We are Seascape Photographer.  We take and supplylandscape photographs.

How do we collect information from you?

We obtain information about you when you use our services.

What information is being collected?

Clients & suppliers - names, work addresses, work telephone numbers, personal telephone numbers, email addresses.

Employees - Tax & National Insurance details, DBS details, application details, pay information, addresses, personal telephone numbers, email addresses, passports.

Who is collecting it?

Employees of Seascape Photographer and our website provider, Art Storefronts.

How is it collected?

By personal contact by using our website www.seascapephotographer.co.uk

Why is it being collected and how will it be used?

To enable Seascape Photographer to take payments for landscape photograph orders, contact and inform clients and to provide a service to our customers.

 

Who will it be shared with?

Information will be shared with HMRC ( HM Revenue & Customs) together with sub-contractors where personal information is required to fulfill a contract with us.

Identity and contact details of any data controllers                   

Roy Fraser

07836205629

 

Retention period

Information need will be assessed twice a year or on contact by individuals.

Your Choices

You have a choice about whether or not you wish to receive information from us.  If you do not want to receive direct marketing communications from us you can select your choices by ticking the relevant boxes situated on the form on which we collect your information.

 

We will not contact you for marketing purposes by email, phone or text message unless you have given your prior consent.  We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted.  You can change your marketing preferences at any time by contacting us by email  royfraser@btconnect.com or telephone on 07836205629

How you can access and update your information

The accuracy of your information is important to us.  If you change email address, or any of the other information we hold is inaccurate or out of date, please email us at royfraser@btconnect.com Alternatively you can telephone 07836205629

You have the right to ask for a copy of the information we hold about you (we will charge £10 for information requests) to cover our costs in providing you with details of the information we hold about you.

 

Security precautions in place to protect the loss, misuse or alteration of your information

When you give us personal information, we take steps to ensure that it's treated securely.  Any sensitive information is stored securely on our Amazon Server.

Once we receive your information, we make our best effort to ensure its security on our systems.

Reporting breaches

All members of staff have an obligation to report actual or potential data protection compliance failures to the data controller

(Roy Fraser).  This allows us to:

Investigate the failure and take remedial steps if necessary.

Monitoring

Everyone must observe this policy.  Roy Fraser has overall responsibility for this policy.  He will monitor it regularly to make sure it is being adhered to. 

Consequences of failing to comply

We take compliance with this policy very seriously.  Failure to comply puts both you and the Company at risk.

If you have any questions or concerns about anything in this policy, do not hesitate to contact Roy Fraser.

Review of this Policy

We keep this Policy under regular review.  This Policy was last updated in March 2018.

 

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