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info@thomasbbonnett.co.uk
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THOMAS B. BONNETT

(Janet, Christopher and Paul Stocking)

HARDWARE AND BESPOKE IRONWORK

Tel: (01366) 500295    Fax: (01366) 500053 LYNN ROAD, STOKE FERRY, KING’S LYNN. PE33 9SW

Email: info@thomasbbonnett.co.uk     www.thomasbbonnett.co.uk

Data protection policy

Context and overview   

Key details

  • Policy prepared by:            ______Heidi Wellington______
  • Approved by partners on:        _______1st May 2018_________
  • Policy became operational on:    ______25th May 2018_________
  • Next review date:            ______1st May 2019__________

 

Introduction

Thomas B. Bonnett needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people the company 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 Thomas B. Bonnett:

  • Complies with data protection law and follows 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 GDPR (General Data Protection Regulation) describes how organisations, including Thomas B. Bonnett, must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or 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 eight important principles. These state that individuals have specific rights regarding their personal data:

  1. The right to be informed – to know what details are to be kept, for what time period, how they will be used, why needed and who has access to them
  2. The right of access – individuals should be able to access their data to confirm how it’s processed and allow them to verify the process is lawful
  3. The right of rectification – the right to have information kept complete and up-to-date including with any third parties it has been shared with
  4. The right to erasure – the ability to request to have data removed once there’s no further reason to hold it
  5. The right to restrict processing – ability to block or restrict the processing of their data
  6. The right to data portability – to obtain and safely reuse their data across different services
  7. The right to object – to data processed due to legitimate interest, profiling, direct marketing or for purposes of scientific/historical research and statistics.
  8. The right ‘not to be subject to a decision’ – based on an automated process, or if it produces a legal effect or similar significant effect on an individual

 

People, risks and responsibilities

Policy scope

This policy applies to:

  • All staff and volunteers of Thomas B. Bonnett
  • All contractors, suppliers and other people working on behalf of Thomas B. Bonnett

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:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • …plus any other information relating to individuals

 

Data protection risks

This policy helps to protect Thomas B. Bonnett from data security risks, including:

  • Breaches of confidentiality – information being given out inappropriately
  • Failing to offer choice – all individuals should be free to choose how the company uses data relating to them
  • Reputational damage – the company could suffer if hackers gained access to sensitive data

 

Responsibilities

Everyone who works for or with Thomas B. Bonnett has some responsibility for ensuring data is collected, stored and handled appropriately.

Each person that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

 

These people have key areas of responsibility:

  • The partners, Christopher, Paul and Janet Stocking, are ultimately responsible for ensuring that Thomas B. Bonnett meet its legal obligations.
  • The data protection officer, Heidi Wellington, is responsible for:
    • Keeping the partners updated about data protection responsibilities, risks and issues.
    • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
    • Arranging data protection training and advice for people covered by this policy.
    • Handling data protection questions from staff and anyone else covered by this policy.
    • Dealing with requests from individuals to see the data Thomas B. Bonnett holds about them.
    • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
  • The IT manager, Paul Stocking, is responsible for:
    • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
    • Performing regular checks and scans to ensure security hardware and software is functioning properly.
    • Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
  • The marketing manager, Elaine Taylor, is responsible for:
    • Approving any data protection statements attached to communications such as emails, quotes, contracts and letters.
    • Addressing any data protection queries from media outlets or other third parties.
    • Where necessary, working with other staff to ensure any marketing initiatives, website links and such abide by data protection principles.

 

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. When access to confidential information is required, employees can request it from the office.
  • Thomas B. Bonnett will provide training to all employees to help them understand their responsibilities when handling data.

 

  • All employees should keep data secure, by taking sensible precautions and following the guidelines below.
  • In particular, 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.
  • Employees should request help from a manager or the data protection officer if they are unsure about any aspect of data protection.

 

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data protection officer.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that it usually stored electronically but has been printed out for some reason:

  • When not in use, the paper or files should be kept in a locked drawer or filing cabinet.
  • Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a desk or 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, 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 system.
    • Servers containing personal data should be sited in a secure location, away from generally accessed office space.
    • Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard back-up 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 Thomas B. Bonnett 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, employees should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
  • Personal data should never be transferred out of the European Economic Area.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

 

Data accuracy

The law requires Thomas B. Bonnett to 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 effort Thomas B. Bonnett should put into ensuring its accuracy.

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 will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
  • Thomas B. Bonnett will make it easy for data subjects to update the information Thomas B. Bonnett holds about them. For instance, via the company website.
  • 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 data base.
  • It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

 

Subject access requests

All individuals who are the subject of personal data held by Thomas B. Bonnett are entitled to:

  • Ask what information the company 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 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 the data controller at Thomas B. Bonnett. The data controller can supply a standard request form, although individuals do not have to use this.

The data controller will always verify the identity of anyone making a subject access request before handing over any information, and aim to provide the relevant data within 40 calendar days.

 

Disclosing data for other reasons

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 Thomas B. Bonnett will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the partners and from the company’s legal advisors where necessary.

 

Providing information

Thomas B. Bonnett aims to ensure that individuals are aware that their data is being processed, and that they understand:

  • How 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 being used by the company.

This is available on request. A version of this is also available on the company’s website.