E File UK Ltd (also trading as TradeShredders.com) 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. They can also include data stored on behalf of customers which may include medical records, financial records, human resources records and other sensitive data.
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 the law.
Why this policy exists
This policy ensures E File UK Ltd:
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;
Minimises risks of data loss.
Data Protection law
The Data Protection Act 2018 describes how organisations must collect, handle and store personal information.
NOTE: This is based on the assumption that the new UK Data Protection Act is published on schedule.
This policy applies 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 lawfully and fairly;
2. not be processed in a manner incompatible with the purpose for which it collected;
3. be adequate, relevant and not excessive;
4. be accurate and, where necessary, kept up to date;
5. be kept for no longer than necessary;
6. be processed in a manner that ensures the appropriate security.
NOTE: Based on the Data Protection Bill published 18thy January 2018.
This policy applies to all staff, branches, volunteers, suppliers and other people working on behalf of E File UK Ltd
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. This can include:
Names and addresses of individuals;
Contact details of individuals;
Other personal and corporate data.
Data security risks
This policy helps to protect E File UK Ltd and its customers from 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;
loss of data. For instance, from natural disasters, accidental or malicious damage.
Everyone who works for or with E File UK Ltd 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 board of directors is ultimately responsible for ensuring that E File UK Ltd meets its legal obligations;
The data protection officer, is responsible for:
Keeping the board 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 E File UK Ltd 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 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;
Ensuring all data is securely backed up in remote location and regular tests are carried out to ensure procedures are working correctly
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 managers.
E File UK Ltd 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 these guidelines.
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 have an open attitude towards sharing any security or data protection concerns with their line manager or appropriate person.
Employees should 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 should be safely stored. Questions about storing data safely can be directed to the IT manager or Data Protection Officer.
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 room or filing cabinet.
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 room 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 these should be password protected and 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 supplier or authorised customer.
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 and a firewall.
Minimising data loss
Physical documents will be protected from potential loss due to natural disasters, accidental or malicious damage.
Data should be transported using employed staff in roadworthy vehicles, couriers should not be used unless specifically authorised by the customer.
Data should not be left in vehicles unattended.
Data should not be stored in a basement area or directly on any floor but instead on suitable shelving raised off floor level to minimise any risk of flood damage. A gap should be left between any shelving and outer walls so documents are not touching any walls.
Storage areas should remain locked at all times unless in use by authorised staff.
Areas where sensitive data is being stored or used should always be in an area only accessible through security coded door entry.
Doors should be self-closing to reduce fire risk. Water based and where applicable carbon dioxide based fire extinguishers should be available in all areas of the premises.
Smoke detectors should be installed and tested regularly covering all areas of the premises.
Smoking is not permitted anywhere on the premises.
CCTV should be used in all areas containing sensitive data.
All staff accessing sensitive data should be DBS checked and no contract staff should be used.
When confidential data is accessed and used it can be at the greatest risk of loss, corruption or theft:
When working with confidential data, employees should ensure the screens of their computers are always locked when left unattended.
Confidential 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 IT manager can explain how to send data to authorised external contacts.
Confidential data should never be transferred outside of the European Economic Area.
Employees should not save copies of confidential data to their own computers. Always access and update the central copy of any data.
The Data Protection Act requires E File UK Ltd 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 copies.
Staff should take every opportunity to ensure data is updated where necessary.
Data should be updated as inaccuracies are discovered.
When data is destroyed or shredded it should be:
carried out on site in a secure and safe fashion or securely transported using sealed containers to an approved shredding supplier.
Subject access requests
All individuals who are the subject of personal data held by E File UK Ltd in its role as a data controller 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.
Subject access requests from individuals should be made by email, addressed to firstname.lastname@example.org. E File UK Ltd can supply a standard request form, although individuals do not have to use this.
E File UK Ltd will aim to provide the relevant data within 14 days.
E File UK Ltd 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, E File UK Ltd will disclose requested data. However, E File UK Ltd will ensure the request is legitimate, seeking assistance from the board and from the company's legal advisers where necessary.
E File UK Ltd 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: here