The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
Step Into Reality needs to gather and use certain information about individuals in the course of its business.
These individuals can include customers, consultants, suppliers, 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 processed i.e. collected, handled and stored to meet the company’s data protection standards and remain compliant with GDPR requirements for personal data.
The definition of personal data provides for a wide range of personal identifiers, including name, identification number, location data or email addresses and telephone numbers.
The GDPR applies to both automated personal data and to manual filing systems where personal data are accessible according to specific criteria. This could include chronologically ordered sets of manual records containing personal data.
This policy applies to Step Into Reality Ltd: –
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include as a minimum:
Plus any other information relating to individuals
Article 5 of the GDPR requires that personal data shall be:
a) processed lawfully, fairly and in a transparent manner in relation to individuals;
b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
This policy helps to protect Step Into Reality from some very real data security risks, including:
Everyone who works for or with Step Into Reality has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that 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:
These rules describe how and where data will be safely stored at Step Into Reality. Questions about storing data safely can be directed to the IT Manager or Data Protection Officer.
When data is stored on paper, it will be kept under lock and key at the head office of where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
Employee personal information will be stored electronically in the HR area of Sharepoint (cloud) where access is restricted to the Board of Directors and is protected from unauthorised access, accidental deletion and malicious hacking attempts. Consultant personal information will be stored where access is restricted to employees of Step Into Reality who have a legitimate need to access such data. Personal information belonging to clients and business associates will be stored electronically in the CRM Salesforce and accessed by licensed authorised Step Into Reality employees.
Personal data is of no value to Step Into Reality 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:
All individuals who are the subject of personal information held Step Into Reality are entitled to:
The Data Protection Officer will always verify the identity of anyone making a subject access request before handing over any information.
In certain circumstances, the GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Step Into Reality will disclose requested data. However, the Data Protection Officer will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Step Into Reality aims to ensure that individuals are aware that their data is being processed, and that they understand:
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 Privacy Statement page.