Exponential Training regards the lawful and correct treatment of personal data as very important.
Data Protection Policy
- Policy prepared by: John Moore, Managing Director
- Approved by Director on: 22 December 2017
- Next review date: 22 December 2018
Exponential Training & Assessment needs to gather and use certain information about individuals. These can include customers, suppliers, partners, 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 legislation including the Data Protection Act (DPA) and the General Data Protection Regulation (GDPR). The policy encompasses all aspects of data protection and security surrounding confidential company information and must be distributed to all company employees. All employees must read this document in its entirety and sign the form confirming they have read and understand this policy fully. This document will be reviewed and updated by Directors annually or when relevant to include newly developed security standards into the policy and distributed to all employees and contracts as applicable.
2. Why This Policy Exists
The data protection policy ensures Exponential Training:
- complies with data protection law and follows good practice;
- protects the rights of staff, customers, learners, partners and other individuals;
- is open about how it stores and processes individuals’ data;
- protects itself from the risks of a data breach.
The DPA is underpinned by eight important principles which 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 held for any longer than necessary;
- Be processed in accordance with the rights of data subjects;
- Be protected inappropriate ways;
- Not transferred outside the European Economic Area unless that country or territory also ensures an adequate level of protection.
People, Risks and Responsibilities
3. Policy Scope
This policy applies to:
- All directors, managers and employees;
- All associate consultants, contractors, suppliers and other people working on behalf of Exponential Training.
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||· E-mail addresses||· Telephone numbers|
|· Postal address||· Usage of company websites||· Employee records|
Other information relating to individuals may be collected and stored (e.g. relating to job applications, employment history and training courses/qualification programmes).
4. Data Protection Risks
This policy helps to protect Exponential Training from some very real data security risks, including:
- Breaches of confidentiality (e.g. information being given out inappropriately);
- Failing to offer a choice (e.g. all individuals should be free to choose how the company uses data relating to them);
- Reputational damage (e.g. the company could suffer if hackers successfully gained access to sensitive data).
Everyone who works for or with Exponential Training has some responsibility for ensuring data is collected, stored and handled appropriately. Team members that handle personal data must ensure that it is handled and processed in line with this policy, and data protection principles. However, the following people have key areas of responsibility:
- The Board of Directors is ultimately responsible for ensuring that Exponential Training meets its legal obligations;
- The Data Protection Officer (DPO), John Moore, Managing Director, is responsible for:
- Keeping the Board of Directors 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 that Exponential Training holds about them (also known as ’subject access requests’);
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
The Managing Director, John Moore, is responsible as the IT manager for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards and are functioning correctly;
- Evaluating any third-party services the company is considering using to store or process data (e.g. cloud computing services).
The Managing Director, John Moore, is responsible as the Marketing manager for:
- Approving any data protection statements attached to communications such as emails and letters;
- Addressing any data protection queries from journalists or media outlets such as newspapers;
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
6. General Employee 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, team members can request it from their line manager and/or colleagues;
- Exponential Training will provide training to all team members to help them understand their responsibilities when handling data (e.g. during induction, continuing training);
Employees should keep all data secure, by taking sensible precautions and following the guidelines outlined below;
- Strong passwords must be used, and they should not be shared;
- Personal data should not be disclosed to unauthorised people, even within the company or externally;
- Data should be regularly reviewed and updated. If it is found to be out of date, or if no longer required, it should be deleted and if necessary disposed of in a suitable way;
- Employees should request help from their line manager or the DPO if they are unsure about any aspect of data protection.
7. Data Storage
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the DPO.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see and access 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 filing cabinet;
- Employees should make sure paper printouts are not left where unauthorised people could see them (e.g. 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 (e.g. CD, DVD or a USB thumb drive), it 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 service;
- Servers containing personal data should be cited in a secure location, away from general office space;
- Data should be backed up frequently and tested regularly, in-line with the company’s backup procedures or the procedures of the cloud service supplier;
- Data should not be stored directly to laptops or other mobile devices such as tablets or smartphones;
- All servers and computers containing data should be protected by approved security software and a firewall.
8. Data Use
Personal data is of no value to Exponential Training 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 the computers are always switched off when left unattended;
- Personal data should not be shared informally and should never be sent by email, as this form of communication is not secure;
- Data must be encrypted before being transferred electronically;
- Personal data should never be transferred outside of the European Economic Area;
- Team members should not save copies of personal data to their own computers, but instead always access and update the central copy of any data.
9. Data Accuracy
The law requires Exponential Training to take reasonable steps to ensure data is kept accurate and up-to-date. The more important it is that personal data is accurate, the greater effort. Exponential Training 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. The following guidelines will be adopted:
- Data will be held in as few places as necessary and team members should not create any unnecessary additional datasets;
- Team members should take every opportunity to ensure data is updated (e.g. by confirming a customer’s details during telephone calls);
- Exponential Training will make it easy for data subjects to update the information that the company holds about them (e.g. via the company website);
- Data should be updated as soon as inaccuracies are discovered (e.g. if the customer can no longer be reached on their stored telephone number, it should be removed from the database).
10. Subject Access Requests
All individuals who are the subject of personal data held by Exponential Training 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 Exponential Training 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 firstname.lastname@example.org. The DPO can supply a standard request form, although individuals do not have to use this.
Individuals will be charged £10.00 per subject access request. The DPO will aim to provide relevant data within 14 days. The DPO will always verify the identity of anyone making a subject access request for handing over any information.
11. Disclosing Data for Other Reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to lawful enforcement agencies without the consent of the data subject. Under these circumstances, Exponential Training will disclose the requested data. However, the DPO will ensure the request is legitimate, seeking assistance from external company legal advisers where necessary.
12. Providing Information
Exponential Training 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: www.exponentialtraining.com.
Note: Exponential Training is registered with the Information Commissioner according to the requirements of the Data Protection Act 1998 (Number Z7379432).