HITE Data Protection Policy
Context and overview
HITE needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data is 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 that HITE
Complies with data protection law and follow good practice
Protects the rights of 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 HITE - 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 principles. 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
This policy applies to:
The HITE registered office
All locations where HITE directors and associates work
All contractors, suppliers and other people working on behalf of HITE
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
…plus any other information relating to individuals
Data protection risks
This policy helps to protect HITE 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.
HITE Directors, assistants and associates have some responsibility for ensuring data is collected, stored and handled appropriately.
Anyone who 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 directors are ultimately responsible for ensuring that HITE meets its legal obligations.
The administrator, Ian Rennie, is responsible for:
Keeping the 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 anyone covered by this policy.
Dealing with requests from individuals to see the data which HITE 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.
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.
Evaluating any third-party services the company might consider using to store or process data.
The Directors are responsible for:
Approving any data protection statements attached to communications such as emails and letters.
Addressing any data protection queries from journalists or media outlets like newspapers.
HITE is a lean organisation and the only people able to access data covered by this policy need it for their work.
Data is not shared informally.
Data is kept secure by taking sensible precautions including:
Strong passwords which are never be shared.
Personal data is never disclosed to unauthorised people, either within the company or externally.
Data is regularly reviewed and updated if it is found to be out of date. If no longer required, it is deleted and disposed of.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
This also applies to data that is usually stored electronically but has been printed out for some reason:
Data printouts are destroyed and disposed of securely when no longer required.
When data is stored electronically, it is protected from unauthorised access, accidental deletion and malicious hacking attempts:
Data is protected by strong passwords
Data is not stored on removable media (like a CD or DVD).
Data is stored on designated drives and servers or approved cloud services.
Servers containing personal data are sited in a secure location.
Data is backed up frequently. Those backups are tested regularly.
Data is never saved directly to laptops or other mobile devices like tablets or smart phones.
All servers and computers containing data are protected by approved security software and hardware.
Personal data is of no value to HITE unless the business can make use of it. To keep it safe we:
Ensure our computers are locked when left unattended.
Personal data is never shared informally. It is never sent by email unless requested by the individual concerned, as this form of communication is not secure.
The law requires that HITE take reasonable steps to ensure data is kept accurate and up to date.
Data is held in as few places as necessary.
We take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
HITE makes it easy for anyone to ensure that the information we hold about them can be updated.
Data is updated as inaccuracies are discovered.
Subject access requests
All individuals who are the subject of personal data held by HITE 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 should be made by email, addressed to the administrator at firstname.lastname@example.org.
Individuals will be charged £10 per subject access request. The administrator will aim to provide the relevant data within 14 days.
The administrator 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, HITE will disclose the requested data. However, the directors will ensure the request is legitimate and take legal advice where necessary.
HITE aims to ensure that individuals are aware that their data is being held and that they understand:
How the data is 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
If you have any questions / concerns with respect to this policy, please do contact us.
Policy prepared by: Claire Rennie and Kamal Thapen
Approved by directors on: 25 May 2018
Policy became operational on: 25 May 2018
Next review date: 25 May 2019