Privacy Policy

Data Protection Policy

Context and overview

  • Policy prepared by: Cara Wilson-Granat
  • Policy became operational on: June 12th, 2018

Introduction

Cara Wilson-Granat needs to gather and use certain information about individuals. These can include businesses, suppliers, employees and other people whom she has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet her data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures Cara Wilson-Granat:

  • Complies with data protection law and follow good practice;
  • Protects the rights of staff, customers and partners;
  • Is open about how she stores and processes individuals’ data; and
  • Protects herself from the risks of a data breach.

Data protection law

The Data Protection Act 1998 describes how organizations and individuals—including Cara Wilson-Granat—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:

  • 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 be held for any longer than necessary;
  • Processed in accordance with the rights of data subjects;
  • Be protected in appropriate ways; and
  • 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 head office for Cara Wilson-Granat;
  • All contractors, suppliers and other people working on behalf of Cara Wilson-Granat.

It applies to all data that she 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 numbers;
  • …plus any other information relating to individuals

Data protection risks

This policy helps to protect Cara Wilson-Granat 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 she uses data relating to them; and
  • Reputational damage. For instance, she could suffer if hackers successfully gained access to sensitive data.

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.
  • In particular, strong passwords must be used and they should never be shared.
  • Personal data should not be disclosed to unauthorized people, either with Cara Wilson-Granat 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.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to Cara Wilson-Granat. When data is stored on paper, it should be kept in a secure place where unauthorized 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.
  • Cara Wilson-Granat should make sure paper and printouts are not left where unauthorized 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 unauthorized access, accidental deletion and malicious hacking attempts:

  • Data should 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 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 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.

Data use

Personal data is of no value to Cara Wilson-Granat unless she 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, Cara Wilson-Granat should ensure the screens of her computers are always locked when left unattended.
  • Personal data should not be shared informally or with individuals for their own use outside of the current email distribution service.
  • Data must be encrypted before being transferred electronically. For those who reside within the European Union, personal data should never be transferred outside of the European Economic Area.
  • Cara Wilson-Granat should not save copies of personal data to her own computers. Always access and update the central copy of any data.

Data accuracy

The law requires Cara Wilson-Granat 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 Cara Wilson-Granat should put into ensuring its accuracy.

  • Data will be held in as few places as necessary.
  • Cara Wilson-Granat should take every opportunity to ensure data is updated. For instance, by confirming a person’s details when they call.
  • Cara Wilson-Granat will make it easy for data subjects to update the information Cara Wilson-Granat holds about them.
  • Data should be updated as inaccuracies are discovered.

Subject access requests

All individuals who are the subject of personal data held by Cara Wilson-Granat are entitled to:

  • Ask what information the organization 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 organization is meeting its data protection obligations.

If an individual contacts Cara Wilson-Granat requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email, addressed to  cara [at] wordsfromcara [dot] com. Cara Wilson-Granat can supply a standard request form, although individuals do not have to use this. Individuals will be charged $10 per subject access request. Cara Wilson-Granat will aim to provide the relevant data within 14 days. Cara Wilson-Granat 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, Cara Wilson-Granat will disclose requested data.

Providing information

Cara Wilson-Granat 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, Cara Wilson-Granat has created this privacy statement, setting out how data relating to individuals is used by her.