SCDA needs to gather and use certain information about individuals.
Such individuals can include customers, 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 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 SCDA:
Data protection law
The General Data Protection Regulation 2016 (GDPR) describes how organisations — including SCDA must collect, handle and store personal information.
This regulation applies 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 GDPR is underpinned by 7 principles. These say that personal data must be:
1) processed lawfully, fairly and in a transparent manner in relation to individuals;
2) 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;
3) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4) 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;
5) 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
6) 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.
7) SCDA is required to take responsibility for what we do with personal data and how we comply with the other principles. We are required to have measures and records in place to be able to demonstrate our compliance
This policy applies to:
It applies to all data and personal information that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:
Data protection risks
This policy helps to protect SCDA and individuals from some very real data security risks, including:
Everyone who works for or with SCDA has some responsibility for ensuring data is collected, stored and handled appropriately. Failure to comply with the requirements of this policy will be viewed very seriously by SCDA, investigated thoroughly and may ultimately lead to disciplinary action being taken under SCDA’s Disciplinary Policy and Procedure, up to and including dismissal.
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 should be safely stored. Questions about storing data safely can be directed to the Data Protection Lead.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it. Whenever possible the secure place should be a locked filing cabinet, ideally kept in a room which is also locked when unattended.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
SCDA regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal. SCDA intends to ensure that personal information is treated lawfully and correctly. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
The law requires SCDA to take reasonable steps to ensure data is kept accurate and up to date.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
Data Breach Reporting Plan
SCDA takes its responsibilities for the security of personal information very seriously and will take all reasonable steps to ensure personal data is processed securely and remains available upon request. As part of this approach regular testing will be carried out to ensure this policy is being followed and that data processing and storage methods are secure. Such approaches will include spot checks and audits of manual and electronic systems and 6 monthly penetration tests of our IT system.
The following would constitute a data breach;
If a data breach is discovered, or suspected, it should be reported, as soon as is practicably possible, to the Data Protection Lead or a member of SMT. If we are not the Data Controller we will report the incident to them as soon as is practicably possible and then follow the process described below. If we are the Data Controller the following process only applies.
A Data Breach Report (Link) should be completed by the reporting person and sent to the Data Protection Lead. Whether actual or suspected the breach will be fully investigated by the Data Protection Lead, or a member of the SMT, within such a timeframe as to enable reporting to ICO within 72 hours if required.
Following investigation the following decisions will be made and acted on.
An investigation report, containing findings and recommendations for improvement/change will be prepared by the Data Protection Lead and presented to SMT for consideration.
A log of actual and suspected data breaches will be maintained by the Data Protection Lead and presented to SMT on a regular basis for discussion and review.
Subject access requests
All individuals who are the subject of personal data held by SCDA are entitled to:
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 Data Protection Lead at firstname.lastname@example.org . Staff wishing to make a subject access request should contact the HR department at email@example.com .
The Data Protection Lead 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 General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, SCDA will disclose requested data. However, we will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
If you are contacted by anyone seeking disclosure of data please discuss with your line manager or the Data Protection Lead prior to any disclosure. Failure to comply with this may result in a data breach which in turn may be subject to investigation and possible disciplinary action, in line with the organisation’s Disciplinary Policy
SCDA aims to ensure that individuals are aware that their data is being processed, and that they understand:
To this end SCDA has written a Privacy Notice setting out how data relating to individuals is processed. A copy of the SCDA Privacy Notice is available on our website.
Date of Policy:
Date of Policy Review:
To be reviewed again:
Policy reviewed by:
Policy ratified by:
Data Protection Lead/HR
HR Sub-Committee/SCDA Board