Data Protection Policy

Status

This policy was last updated on 04/01/2018

Introduction

Sherpa Consulting needs to gather and use certain information about individuals.  These 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 Sherpa Consulting's data protection standards and to comply with the law.

Why this policy exists

The data protection policy ensures that Sherpa Consulting:

  • 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 risks of a data breach.

Data protection law

The Data Protection Act 1998 describes how organisations - including Sherpa 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:

  1. Be processed fairly and lawfully.
  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 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 the European Economic Area (EEA) unless that country or territory also ensures an adequate level of protection.

People, risks and responsibilities

Policy Scope

This policy applies to:

  • The head office of Sherpa Consulting
  • All branches of Sherpa Consulting
  • All staff and volunteers of Sherpa Consulting
  • All contractors, suppliers and other people working on behalf of Sherpa Consulting

It applies to all data that the company holds relating to identifiable individuals even of that data technicall falls outside the scope of the Data Protection Act 1998.  This can include:

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

Data protection risks

This policy helps to protect Sherpa Consulting from some very real data security risks including:

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

Responsibilities

Everyone who works for or with Sherpa Consulting has some responsibility for ensuring that data are collected, stored and handled appropriately.  Everyone who handles personal data must ensure that it line with this policy and data protection principles.

The Proprietor and Data Protection Officer, James Hawkins, is responsible for all aspects of data protection and compliance.

Data storage

Data stored on paper must be protected from unauthorised access.  Data stored on paper should be securely shredded when no longer required.

Data stored electronically must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords which are changed regularly.
  • 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 approved cloud computing services.
  • Servers containing personal data should be sited in a secure location.
  • Data should be backed up frequently.
  • 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 Sherpa Consulting unless the business can make use of it.  However, is is when personal data is accessed and used that it can be as the greatest risk of loss, corruption or theft:

  • When working with personal data, screens of computers should always be locked when left unattended.
  • Personal data should not be shared informally.  In particular, it should never be sent unencrypted by email as this form of communication is insecure.
  • Data must be encrypted before being transferred electronically.
  • Personal data should not be transferred outside the European Economic Area unless adequate data security can be guaranteed.

Data accuracy

The law requires that Sherpa Consulting takes reasonable steps to ensure that personal data are kept accurate and up to date.  

  • Data will be held in as few places as necessary.
  • Every opportunity should be taken to ensure that data is updated.
  • Data should be updated as soon as inaccuracies are discovered.

Subject access requests

All individuals who are the subject of personal data held by Sherpa Consulting 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 daye
  • Be informed how the company is meeting its data protection obligations.

If an individual contacts Sherpa Consulting requesting this information, this is called a subject access request.

Subject access requests should be made by email addressed to the data controller at [email protected]  The data controller will aim to provide the relevant data within 14 days.

The data controller 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 Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.  Under these circumstances Sherpa Consulting will disclose the requested data having ensured that the request is legitimate.

Providing information

Sherpa Consulting 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.