The Data Protection Act 1998 describes how organisations — including Elle Bright — 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. 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.

This policy applies to all staff, volunteers, contractors, suppliers and other people working on behalf of Elle Bright

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. 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 [company name] from some very real data security risks, including:
Breaches of confidentiality. For instance, information being given out inappropriately.

  • Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
  • Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities
Everyone who works for or with Elle Bright has some responsibility for ensuring data is collected, stored and handled appropriately.

The owner-operator is ultimately responsible for ensuring that Elle Bright meets its legal obligations including

dealing with requests form individuals to see the data Elle Bright holds about them (also called ‘subject access requests’).
checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
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.

Data Storage

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 is usually stored electronically but has been printed out for some reason:
When not required, 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 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 (like a CD or DVD), 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 services.

Servers containing personal data should be sited in a secure location.

Data should be backed up frequently.

Those backups should be tested regularly, in line with the company’s standard backup procedures.

Data should never be saved directly to laptops or other mobile devices like tablets or smart phones except for approved use.

All servers and computers containing data should be protected by approved security software and a firewall.

Data Accuracy

It is the responsibility of Elle Bright, it’s employees and contractors to take reasonable steps to ensure that data is kept as accurate and up to date as possible.

Subject Access Requests

All individuals who are the subject of personal data held by Elle Bright 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 Elle Bright at elle@ellebright.com.

Individuals may be charged £10 per subject access request.

Elle Bright will aim to provide the relevant data within 14 days.

Elle Bright 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, [company name] will disclose requested data. However, Elle Bright will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.

Providing Information

Elle Bright 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 policy, 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 Elle Bright’s website at www.ellebright.co.uk/privacy-policy.]

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