GOTO EVENTS DATA PROTECTION POLICY 2018
CONTEXT AND OVERVIEW Key Details Policy prepared by: Sarah Hockney Approved by management on: May 2018 Policy became operational on: May 2018 Next Review Date: May 2019 Introduction GOTO Events 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 the companies data protection standards – and to comply with the law. Why this policy exists This data protection policy ensures GOTO Events: • Complies with data protection law and follow good practice • Protects the rights of staff, customers and partners • Is open about how it stores and processes individual’s data • Protects itself from the risk of data breach Data Protection Law The Data Protection Act describes how organisations including GOTO Events must collect, handle and store personal information. These rules apply 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: • Be processed fairly and lawfully • Be obtained only for specific, lawful use • Be adequate, relevant and not excessive • Be accurate and kept up to date • Not to be held for any longer than necessary • Processed in accordance with the rights of data subjects • Be protected in appropriate ways • Not to be transferred outside of the European Economic Area, unless that country or territory also ensures an adequate level of protection PEOPLE, RISKS & RESPONSIBILITY Policy Scope This policy applies to: • The head office of GOTO Events • All offices of GOTO Events • All staff, freelancers and volunteers of GOTO Events • All contractors, suppliers and other people working on behalf of GOTO Events It applies to all data the company holds relating to identifiable individuals, even if that information falls outside of the Data Protection Act. This can include: • Names of individuals • Postal addresses • E-mail addresses • Telephone numbers • …. Plus any other information relating to individuals Data Protection Risks This policy helps to protect GOTO Events from some very real data security risks, including: • Breaches in 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 GOTO Events has some responsibility for ensuring data is collected, stored and handled appropriately. Each team that handles personal data must ensure it is handled and processed in line with this policy and data protection policy. However, these people have key areas of responsibility: • The directors are ultimately responsible for ensuring that GOTO Events meets it’s legal obligations. • The data protection officer, Sarah Hockney, is responsible for: o Keeping the directors updated about data protection responsibilities, risks and issues o Reviewing all data protection procedures and related policies, in line with an agreed schedule o Arranging data protection training and advise for the people covered in this policy o Handling data protection questions from staff and anyone else covered by this policy o Dealing with requests from individuals to see the data GOTO Events holds about them (also called subject access requests) o Checking and approving any contracts and agreements with third parties that may handle the company’s sensitive data • The IT manager, is responsible for: o Ensuring all systems, services and equipment used for storing data meet acceptable security standards o Performing regular checks and scans to ensure security hardware and software is functioning properly o Evaluating any third-party service’s the company is considering using to store or process data. For instance, cloud computing services. • The marketing manager, Steve Perkins, is responsible for: o Approving any data protection statements attached to communications such as e-mails and letters o Addressing any data protection queries from journalists or media outlets such as newspapers o Where necessary, working with other staff to ensure marketing initiatives 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 their line managers. • GOTO Events will provide training to all employees to help them understand their responsibilities when handling data. • Employees should keep all 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 their line manager or 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 controller. 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 or print outs 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, 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, away from general office space. • Data should be backed up frequently. Those backups should be tested regularly, in line wit the company 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 firewall. DATA USE Personal data is of no value to GOTO Events 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 unattended. • Personal data should not be shared informally. • 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 outside of the European Economic Area. • Employees should not save copies of personal data to their own computer. Always access and update the central copy of any data. DATA ACCURACY The law requires GOTO Events to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is correct, the greater the effort GOTO Events should put into ensuring it’s accuracy. It is the responsibility of all employees who work with data to 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 unnecessary additional data sets. • Staff should take every opportunity to ensure data is updated. For instance, confirming a customer’s details when they call. • GOTO Events will make it easy for data subjects to update the information GOTO Events holds about them. For instance, via the company website. • Date 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 database. • It is the marketing managers 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 GOTO Events 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 e-mail, addressed to the data controller (firstname.lastname@example.org). The data controller can supply a standard request form, although individuals do not have to use this. Individuals will be charged £10 per subject access request. The data controller will aim to provide the 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 GOTO Events will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the directors and company’s legal advisers where necessary. PROVIDING INFORMATION GOTO Events 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. (This is available on request. A version of this statement is also available on the company’s website). Out Of The Office Ltd trading as GOTO Events.
This (www.gotoevents.co.uk) site is a UK based website and takes reasonable care to comply with requirements of the UK Data Protection Act 1998 with regard to the personal information you supply on this site. The GOTO Events site uses a security system that protects your information from unauthorised use. However, as no data transmissions over the Internet can be guaranteed to be 100% secure we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.
Data collectionThis site collects personal data from you via web forms, and also via email addresses we provide so that you contact us with enquiries and send us your details. You submit information using these methods voluntarily, and agree to the use of the personal data you provide as described in this policy.If you give us personal information about somebody else, such as a colleague, we will assume you have their permission to do so, and their data will also be subject to this policy. Data collection via cookies GOTO Events may also collect personally identifying information using cookies.
GOTO Events does not share, sell, trade or rent your personal data outside of the GOTO Events group. We may choose to do so in future with selected third parties whose products and services we think you will find interesting. You can choose not to receive this information by sending a blank email to GOTO Events (email@example.com) with the subject ‘No 3rd Party Information’.Data usage links to external websites.
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, GOTO Events cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.