Privacy Policy
INTRODUCTION
Cave Fitness Leek, as an operational need for its business, needs to gather, use and retain certain information about individuals who have either transacted with Cave Fitness Leek or shown an interest in what Cave Fitness Leek do. These can include: customers, suppliers, business contacts, previous customers, employees and other individuals who have an interest in Cave Fitness Leek and who the company may need to make with during the course of its business.
This policy describes how this personal data will be collected, handled and stored and for how long it will be kept, in order to strictly comply with the company’s own policy and data protection standards – and to comply with the law.
WHY THIS POLICY EXISTS
This Data Protection Policy exists to ensure that Cave Fitness Leek:
• Complies with Data Protection laws and follows good practice.
• Protects the rights of employees, customers, and suppliers.
• Is transparent about how it stores, processes and disposes of personal information and data
• Protects itself from the risk of breaches of data security.
DATA PROTECTION LAW
The Data Protection Act 1998 proscribes how organisations (including Cave Fitness Leek) must collect, protect and store personal information held on individuals. These rules must be adhered to regardless of how the data is stored e.g. electronically, on paper or digitally. To comply with the law data must be collected, and processed fairly, stored securely, and not disclosed unlawfully.
The Data protection Act is underpinned by eight guiding principles. Data must:
1. Be processed lawfully and fairly
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 to be held for any longer than necessary.
6. Be processed in accordance with the rights of Data Subjects.
7. Be protected in appropriate ways.
8. Not be transferred outside of the European Economic Area (EEA), unless that country or territory also ensures adequate levels of protection.
People, Risks, and Responsibilities
POLICY SCOPE
This Policy applies to:
• The Head Office of Cave Fitness Leek
• All employees and staff of Cave Fitness Leek
• Contractors, sub-contractors and suppliers to Cave Fitness Leek and any other persons working on behalf of Cave Fitness Leek.
It applies to all data held by Cave Fitness Leek relating to identifiable individuals, even if that data, technically falls outside of the scope of the Data Protection Act 1998. This will include:
• Names of individuals
• Postal Addresses
• E-mail addresses
• Telephone Numbers
• Any other information relating to individuals.
DATA PROTECTION RISKS
This policy helps to protect Cave Fitness Leek from data security risks, including:
• Breaches of Confidentiality – For instance names and addresses be given out inappropriately.
• Failing to Offer Choice – For instance, all individuals should be free to choose how the company treats data relating to them.
• Reputational Damage – For instance, the company could suffer if hackers successfully gained access to sensitive data.
RESPONSIBILITIES
Everybody who works for, or with, Cave Fitness Leek has a responsibility for ensuring that data is collected, processed, and stored appropriately. Each Team that handles personal data must ensure that it is collected, processed and stored in compliance with this policy and The Eight Data Protection Principles.
However, there are key areas of responsibility:
The Directors are ultimately responsible for ensuring that Cave Fitness Leek meets its legal obligations.
The Data Protection Officer, is responsible for:
• Keeping the Directors updated about Data Protection responsibilities, risks and issues
• Reviewing all Data Protection Policies and Procedures in line with the prescribed schedule.
• Arranging Data Protection training and advice for all staff covered by this policy
• Handling Data Protection questions and queries from all people covered by this policy
• Dealing with requests from individuals to witness the Data that Cave Fitness Leek holds about them (also called, “Subject Access Requests”).
• Checking and approving any contracts or agreements made with third parties that my process Cave Fitness Leek's sensitive data.
The Information Technology Manager, is responsible for:
• Ensuring that all systems, services, and equipment used for storing personal information meets acceptable security standards
• Performing regular checks and scans to ensure that security hardware and software is functioning properly.
• Evaluating third party services which Cave Fitness Leek already use or are contemplating using to store or process data.
The Director, is responsible for:
• Approving all data protection statements attached to communications issued by Cave Fitness Leek.
• Addressing any Data Protection enquiries from the media or professional bodies.
• Work with other staff and contractors to ensure that Marketing Programmes abide by the Eight Data Protection Principles.
GENERAL STAFF GUIDELINES
• The only people able to access personal data covered by this policy will be those who need to do so as part of their work
• Data MUST NOT be shared informally. When access to confidential information is required by staff the a request must be made, in the first instance, to their line manager.
• Cave Fitness Leek will provide training to all of those working for, and with, it to help them understand their responsibilities in handling data covered by this policy.
• Employees must keep all data secure, by taking sensible precautions and by following the following guidelines:
• Strong Passwords MUST be used, will never be shared and changed regularly.
• Personal Data WILL NOT be disclosed to unauthorised persons, either within or external to the company.
• Data WILL BE regularly reviewed and updated, and when found to be out of date or no longer required WILL BE deleted and disposed of by following secure procedures.
• Staff WILL request help and assistance from the Data Protection Officer if they are unsure about any aspect of Data Protection.
DATA STORAGE
These rules describe how and where data will be safely stored. Questions about the safe storage of data will be referred to the Director.
Where data is stored on paper it will be kept secure and out of view and access from unauthorised staff. This applies also to data that is normally stored electronically but has been printed.
• When not being processed the data must be kept in a locked cupboard, draw, or filing cabinet.
• Staff WILL ensure that paper and printouts are not left in any place where they can be viewed by unauthorised personnel.
• Data held on paper and printouts MUST be destroyed by shredding once they have become obsolete or no longer required.
When Data is stored electronically it MUST be protected from being viewed or accessed by unauthorised personnel, being accidentally deleted, or maliciously hacked:
• Access to computer systems and hardware where data is stored will be protected by strong passwords which are never shared and changed often.
• Where data is stored on removable media (e.g. DVD) this must be stored securely in locked cupboards, draws, or filing cabinets when not being used.
• Data must only be stored on designated devices and drivers and will only be uploaded to an approved cloud computing service.
• Servers containing Personal Data should be sited in a secure location and away from general open access office facilities.
• Data WILL be backed up frequently and, in line with company back up procedures and schedules, tested regularly.
• Data WILL NOT be saved directly to laptops or other mobile devices
• All servers and computers storing Personal Data will be protected by approved security software and a firewall.
DATA USE
Personal Data is of no use to Cave Fitness Leek unless the business can make use of it. However, it is when Personal Data is in use that the greatest risks occur that can result in data being corrupted, hacked, or lost or stolen:
• When working with Personal Data, staff must ensure that the computer screens are locked when they are not in attendance
• Personal Data will not be shared informally. It should not be sent by e-mail, as this form of communication is not secure.
• Personal Data will be encrypted before being transferred electronically. The Information Technology Manager will advise on sending data to authorised third external contacts.
• Personal Data will never be transferred outside of the European Economic Area.
• Staff will not save Personal Data to their personal laptops or mobile devices. Personal Data will be kept and updated on central copies.
DATA ACCURACY
The law requires that Cave Fitness Leek take reasonable steps to keep data accurate and up to date. The more important it is that the Personal Data is up to date then the more important it is for Cave Fitness Leek to ensure its accuracy.
It is the responsibility of all staff that has access to Personal Data to take reasonable steps to ensure that it is kept accurate and up to date.
• Data will be kept in as few places as necessary. Staff will not create any unnecessary data sets.
• Staff will take every opportunity to ensure that data is kept accurate and up to date, for example by confirming a customer’s details during an incoming phone call
• Cave Fitness Leek will make easy for Data Subjects to update the information that Cave Fitness Leek holds on them, for instance by using the Contact Us form on the website.
• Data should be updated as soon as an inaccuracy is discovered. For instance, if a customer cannot be reached on the telephone number stored then that number should be removed from the data set.
SUBJECT ACCESS REQUESTS
All individuals who are the subject of Personal Data held by Cave Fitness Leek are entitled to:
• To ask what information is held by Cave Fitness Leek and for what reason/purpose.
• To ask how to gain access to that data
• Be informed on how to keep the data up to date
• Be informed how Cave Fitness Leek is meeting its Data Protection obligations.
If an individual makes contact with the company requesting this information it is called a Data Access Request.
Subject Access Requests will be made to the Director of Cave Fitness Leek.
The Director can supply a standard Request Form, although individuals do not have to use this form.
The Director will always verify the identity of anyone making a Subject Access Request before passing on any information.
DISCLOSING DATA FOR ANY OTHER REASON.
In certain circumstances the Data Protection Act allows for Personal Data to be disclosed to Law Enforcement Agencies without the consent of the Data Subject.
Under these circumstances Cave Fitness Leek will disclose the requested data. However, the Data Protection Officer will ensure that the request is legitimate, seeking advice from the Director and the Company’s legal advisors, where necessary.
PROVIDING INFORMATION
Cave Fitness Leek 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 the company has a privacy statement setting out how data relating to individuals is used by the company. This statement is available on request and is also available on the company’s website.