Data Privacy Policy: Declaration of Compliance with the General Data Protection Regulation

Key details
Policy prepared by: Benjamin Black of Blacklarke Consulting Ltd
Policy became operational on: 20/03/2018
Next review date: 20/10/2018


Introduction
Blacklarke Consulting needs to gather and use certain information about individuals. These can include customers, suppliers, busin ess contacts, employe es and o ther 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 the law. Blacklarke Consulting is fully cognisant of its obligations and duties under the General Data Protection Regulation (EU) 2016/679.

Why this policy exists
This data privacy policy ensures Blacklarke Consulting:

  • Complies with data protection law and follow 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


Data protection law
The Data Protection Act 1998 and the General Data Protection Regulation (EU) 2016/679 describe how organisations — including Blacklarke Consulting 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
  • 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 or territory also ensures an adequate level of protection for specific, lawful purposes


Policy scope
This policy applies to:

  • The Head Office of Blacklarke Consulting
  • All contractors, suppliers and other people working on behalf of Blacklarke Consulting


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 and the General Data Protection Regulation (EU) 2016/679.

This can include:

  • Names
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • Any other information relating to individuals


Data protection risks
This policy helps to protect Blacklarke Consulting 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.


Responsibilities
Everyone who works for or with Blacklarke Consulting has some responsibility for ensuring data is collected, stored and handled appropriately.

General 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.
  • Blacklarke Consulting will provide training to any collaborators to help them understand their responsibilities when handling data.
  • All data must be kept securely, by taking sensible precautions and following the guidelines below.
  • 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.


Data storage
When data is stored on paper, it should be kept in a secure place where unauthorised peoople 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. Paper and printouts must not be 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 (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. Severs 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 Blacklarke Consulting 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, the screens of computers are always locked when left unattended. Personal data should not be shared informally. 

Data accuracy
The law requires Blacklarke Consulting to take reasonable steps to ensure data is kept accurate and up to date. Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets. Data is updated at every opportunity. For instance, by confirming a client’s details when they call. Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.

Subject access requests
All individuals who are the subject of personal data held by Blacklarke Consulting are entitled to:

  • Ask what information the company holds about them and
  • Ask how to gain access to
  • Be informed how to keep it up to
  • 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 benjamin@blacklarke.com. We will aim to provide the relevant data within 14 days. The identity of anyone making a subject access request will always be carefully verified before any information is provided.

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, Blacklarke Consulting will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.