GENERAL GDPR POLICY

A)  INTRODUCTION
We may have to collect and use information about people with whom we work.  This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.

We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business.  We will ensure that we treat personal information lawfully and correctly.

To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).

This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our business functions as described below. It also covers our response to any data breach and other rights under the GDPR.

This policy applies to the personal data of our customers, suppliers and other stakeholders. These are referred to in this policy as relevant individuals.

B)  DEFINITIONS
“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.

“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).

“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.

“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

C)  DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

a)  processing will be fair, lawful and transparent
b)  data be collected for specific, explicit, and legitimate purposes
c)  data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
d)  data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
e)  data is not kept for longer than is necessary for its given purpose
f)   data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
g)  we will comply with the relevant GDPR procedures for international transferring of personal data

D)  TYPES OF DATA HELD
We keep several categories of personal data on our customers and suppliers in order to carry out effective and efficient processes. We keep this data on our secured server, in locked filing cabinets and we also hold the data within our computer systems.

Specifically, we hold the following types of data:

a)  company/personal details such as name, address, phone numbers
b)  details relating to company registration numbers, vat number, bank account details and tax codes
c)  pricing information
d)  correspondence such as letters and emails

All of the above information is required for our processing activities.

E)  YOUR RIGHTS
You have the following rights in relation to the personal data we hold on you:

a)  the right to be informed about the data we hold on you and what we do with it;
b)  the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
c)  the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
d)  the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
e)  the right to restrict the processing of the data;
f)   the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
g)  the right to object to the inclusion of any information;
h)  the right to regulate any automated decision-making and profiling of personal data.

F)  RESPONSIBILITIES
In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection.

We have also appointed employees with responsibility for reviewing and auditing our data protection systems.

G)  LAWFUL BASES OF PROCESSING
We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.

Where no other lawful basis applies, we may seek to rely on the individuals’ consent in order to process data.

However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. Employees will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.

H)  ACCESS TO DATA
Customers or suppliers have a right to access the data that we hold on them as stated by law. We will comply with the request in accordance with legislation.

I)  DATA DISCLOSURES
The Company may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:

a)  to assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders or to assess or collect any tax or duty.

These kinds of disclosures will only be made when strictly necessary for the purpose.

J)  DATA SECURITY
No files or written information of a confidential nature are to be left where they can be read by unauthorised people.

K)  THIRD PARTY PROCESSING
Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.

L)  INTERNATIONAL DATA TRANSFERS
The Company does not transfer personal data to any recipients outside of the EEA.

M)  REQUIREMENT TO NOTIFY BREACHES
All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.

More information on breach notification is available in our Breach Notification policy.

N)  RECORDS
The Company keeps records of its processing activities including the purpose for the processing and retention periods in its Company Data Record. These records will be kept up to date so that they reflect current processing activities.

O)  DATA PROTECTION COMPLIANCE
Our Data Protection Officer is:

Name:                         Ray Gold                                    
Contact details:          ray.g@rdgengineering.co.uk   

And will be assisted in respect of our data protection activities by:

Name:                         Darilla Chellen
Contact details:          darilla.c@rdgengineering.co.uk