General Data Protection Regulation Policy
- Policy became operational on: 1st May 2018
- Review date: 1st May 2026
1. Introduction
Alexander Mae Ltd ("the Company") needs to gather and use certain information about individuals in the normal course of its business to enable it trade and sell its services. The Company recognises the importance of the personal data our candidates and temporary employees have entrusted to us and are committed to properly manage, protect and process that personal data.
This can include, but is not limited to, information on candidates, clients, suppliers, business contacts, temporary candidates and other people the Company has a relationship with or may need to contact.
This policy describes how personal data must be collected, handled and stored to meet the Company’s data protection standards and, most importantly, comply with the law.
2. Why this policy exists
This Data Protection Policy ensures that the Company and its officers:
- Comply with data protection law and follow good practice.
- Protects the rights of its candidates.
- Is open about how it stores and processes individuals' data.
- Protects itself from the risks of a data breach.
3. Data Protection Law
The European General Data Protection Regulation (GDPR) rules which come into force on May 25th 2018 describes how organisations, including the Company, 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 European General Data Protection Regulation (GDPR) is underpinned by eight important principles which form the basis of the Company's Policy. In all circumstances personal data must:
- Be processed fairly and lawfully.
- Be obtained by only 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 and territory also ensures an adequate level of protection.
4. People, Risks and responsibilities
4.1 People
This policy applies to:
- All subsidiaries of the Company.
- All temporary employees of the Company.
- All contractors, suppliers and other external agencies working on behalf of the Company.
It applies to all data that the company holds relating to indetifiable individuals, even if that information technically falls outside of the The European General Data Protection Regulation (GDPR). This can include:
- Names of individuals.
- Postal addresses.
- Email addresses.
- Telephone numbers.
- Plus any other personal information relating to individuals.
The Company will follow best practice and the following processes will be adhered to as practically possible:
- 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, it will be via a Subject Access Request process.
- The Company Directors will keep all data secure, by taking sensible precautions and following the guidelines below.
- In particular, strong passwords must 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 should be deleted and disposed of.
4.2 Data Protection Risks
This policy helps to protect the Company from some very real data security risks, including:
- Breaches of confidentiality.
- Failing to offer choice.
- Reputational damage.
4.3 Responsibilities
The Directors of the Company have responsibility for ensuring data is collected, stored and handled appropriately.
Key areas of responsibility:
- The Directors are ultimately responsible for ensuring the Company meets its legal obligations.
- The Data Protection Officer, Kim Richens is responsible for:
- Reviewing all data protection procedures and related policies.
- Handling data protection queries.
- Dealing with requests from individuals to see the data the Company 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.
- Evaluating any third party services the company is considering using to store or process data.
- Approving any data protection statements attached to the communications such as emails and letters.
- Addressing any data protection queries from journalists or media outlets like newspapers.
- Where necessary, working with other third party agencies to ensure marketing iniatives abide by data protection principles.
- The IT Provider, RJW Solutions is responsible for:
- Ensuring all systems, services and equipment for storing data meet acceptable security standards
- Performing regular checks and scans to ensure security hardware and software is functioning properly
5. Providing information
The Company 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.
- They can request non use or data.
- They can, at any time, request removal of data from media such as newsletters, company updates and marketing material and the CRM and records will be updated accordingly .
6. Data Storage
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Data Controller.
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.
- All paper documents and printouts must not be left where unauthorised people visiting the Company could see them, e.g. on a printer or desk.
- Data printouts should be shredded and disposed of securely when no longer required.
- To avoid any external breaches of data confidentiality all visitors must be signed in and out of the office area and accompanied in all restricted areas.
- When data is stored electronically, it must 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.
- If data is stored on removable media (like a cd or dvd), these will be kept in a secure place when not being used.
- Data will only be stored on designated drives and servers, and will only be uploaded to an approved cloud computing system.
- Servers containing personal data will be sited in a secure location, away from general office space.
- Data will be backed up frequently.
- Data will never be saved directly to laptops or other mobile devices like tablets and smart phones.
- All servers and computers containing data will be protected by approved security software and a firewall.
- Records will be updated promptly on the Company's CRM to reflect any change in candidate information (change of address, marketing preferences).
- Any personal information the Company holds on a candidate that is no longer relevant will be deleted in a secure manner after a 24 month period.
- To prevent virus attacks a duty of care must be taken when opening emails and attachments or visiting new websites. If in doubt check with Data Controller.
7. Data use
Use of Personal Data must always be for business trading purposes only and should be held securely as this Policy sets out. However, should personal data be accessed and used that it can be at the greatest risk of loss, corruption or theft:
- When working with personal data, every precaution should be taken to ensure the screens of the computers are always locked when left unattended, in particular when external visitors are visiting the Company.
- Data must be encrypted before being transferred electronically. The IT Manager can explain how to send data to authorised external contacts.
- Personal data should NEVER be transferred outside of the European Economic Area.
- Use of laptops for remote working will require a secure dial up and be fully password protected.
8. Data accuracy
The law requires the Company 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 the Company should put into ensuring its accuracy. It is the responsibility of all Directors of the Company 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.
- Every opportunity will be taken to ensure data is updated e.g. confirming a candidate's details when on the phone.
- The Company will make it easy for data subjects to update the information the Company holds about them e.g. through the company website.
- Data should be updated as inaccuracies are discovered.
9. Subject access requests
All individuals who are the subject of personal data being held by the Company 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, it is called a subject access request.
Subject access requests from individuals should be made by email or post, addressed to the data controller. The data controller will always verify the identity of anyone making a subject access request before handing over any information. All subject access requests will be processed and responded to within one month of such request being received.
Refer to Schedule 1 on how to deal with a SAR (Carol to write SAR Request process)
10. Disclosing data for other reasons
In certain circumstances, The European General Data Protection Regulation (GDPR) act allows personal data to be disclosed to law enforcement agencies without consent of the data subject (individual). Under these circumstances the Company will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the other company directors and legal advisers.
11. Breaches in data protection
There is an obligation to report data protection breaches or contact the Data Protection Officer if they have concerns of such a breach. This will allow the appropriate personnel to investigate further and take the appropriate steps to fix the issue in a timely manner.
12. Third Party External Agencies
The Company confirmes that it has in place arrangements with its third party service providers, including its professional advisers, IT provider and other relevant outsourced suppliers, written agreements setting out parties' roles and responsibilities for data protection.
13. Updates on our Data Protection Policy
As part of our efforts to ensure that we properly manage, protect and process personal data provided to us, we will be reviewing our policies, procedures and processes from time to time. We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion and will circulate the revised policy across the Company as appropriate.
14. The Candidate journey
- The candidate completes an application form and signs our GDR information.
- This information is added to our secure database and candidate records are removed from the database every 12 months once candidates have secured a role, and there paperfile is stored for 12 months in a lockable room.
- The database is housed on the PC which is password protected and has a screensaver when away from your desk
- The candidate application form, CV and any other personal details are stored in a locakable drawer.
- Candidates that temp have their information stored on an on-line portal with their own personal password to access their payslips etc
- Candidate information is destroyed using a confidential waste company that is GDPR compliant
- Information / emails received are also disposed of on a regular basis, unless candidates opt for their CV to remain on file.
Sam Notley
Data Protection Officer