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Skills Provision Limited Data Protection Policy

Skills Provision and associated subsidiaries hold personal data on employees, clients, suppliers, partners and job seekers.

This policy details how personal data is used, handled and stored by all personnel associated with the Skills Provision venture.

Peter Arkwright has been nominated as the Data Protection Officer (DPO) for Skills Provision. He should be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.

Scope

This policy applies to all staff.

You must be familiar with the content and comply with its terms.

This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time.

All new or modified policies will be circulated to staff before being adopted.

Who is responsible for this policy?

As our Data Protection Officer, Peter Arkwright has overall responsibility for the day-to-day implementation of this policy, his email address is dpo@skillsprovision.co.uk

Our procedures

Fair and lawful processing

Skills Provision must process personal data fairly and lawfully in accordance with individuals’ rights. This means we will not generally process personal data unless the individual whose details we are processing has consented to it happening.

The Data Protection Officer’s responsibilities:

  • Review all data protection procedures and policies on a regular basis
  • Arrange data protection training and advice for all staff members
  • Answer all questions on data protection
  • Respond to individuals such as clients and job seekers who wish to know what data is being held on them
  • Check and approve third parties that handle the company’s data
  • Ensure all systems, services, software and equipment meet acceptable security standards
  • Research third-party data related services
  • Approve data protection statements attached to emails and other marketing material
  • Address data protection queries from clients, job seekers and associated personnel

The processing of all data must be:

  • Necessary to deliver our services
  • In our legitimate interests and not unduly prejudice the individual’s privacy

Sensitive personal data

In most cases where we process sensitive personal data we will require the subject’s explicit consent to do this unless exceptional circumstances apply or we are required to do this by law. Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.

Accuracy and relevance

We will endeavour to ensure all personal data we process is accurate, adequate, relevant and not excessive.

Individuals may ask that we correct inaccurate personal data relating to them. If you believe information is inaccurate you should report it to the DPO.

Your personal data

You must take reasonable steps to ensure the personal data we hold on your behalf is accurate and updated as required. For example, if your personal circumstances change, please inform the DPO so our records can be updated.

Data security

You must keep personal data secure against loss or misuse. Where other organisations process personal data on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented.

Storing data securely

  • In cases when data is stored on printed paper, it should be kept in a secure place
  • Printed data should be shredded when it is no longer required
  • Data stored on computers should be protected by strong passwords that are changed regularly.
  • Data stored on CDs or memory sticks must be locked away securely when not in use
  •  The DPO must approve any cloud used for data storage
  • Data should be regularly backed up
  • All servers containing sensitive data must be approved and protected by security software and strong firewalls.

Data retention

We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case.

Transferring data internationally

There are restrictions on international transfers of personal data. You must not transfer personal data anywhere outside the UK without clearance from the DPO.

Subject access requests

Please note that under the Data Protection Act 1998, individuals are entitled, subject to certain exceptions, to request access to information held about them.

If you receive a subject access request, you should refer that request immediately to the DPO.

Please contact the Data Protection Officer if you would like to correct or request information that we hold about you. There are also restrictions on the information to which you are entitled under applicable law.

Processing data in accordance with the individual’s rights

You should abide by any request from an individual not to use their personal data for direct marketing purposes and notify the DPO about any such request.

Do not send direct marketing material to someone electronically (e.g. via email) unless you have an existing business relationship with them.

Please contact the DPO for advice on direct marketing before starting any new direct activity.

Training

All staff will receive training on this policy. New joiners will receive training as part of the induction process. Further training will be provided at least every two years or whenever there is a substantial change in the law or our policy and procedure.

Training will be provided by the DPO

It will cover:

  • The law relating to data protection
  • Our data protection and related policies and procedures.

Completion of training is compulsory.

GDPR provisions

Where not specified previously in this policy, the following provisions will be in effect on or before 25 May 2018.

Privacy Notice – transparency of data protection

Being transparent and providing accessible information to individuals about how we will use their personal data is important for our organisation. The following are details on how we collect data and what we will do with it:

What information is being collected?
Who is collecting it?
How is it collected?
Why is it being collected?
How will it be used?
Who will it be shared with?
Identity and contact details of any data controllers
Details of transfers to third country and safeguards
Retention period

Conditions for processing

We will ensure any use of personal data is justified using at least one of the conditions for processing and this will be specifically documented. All staff who are responsible for processing personal data will be aware of the conditions for processing. The conditions for processing will be available to data subjects in the form of a privacy notice.

Justification for personal data

We will process personal data in compliance with all six data protection principles.

We will document the additional justification for the processing of sensitive data, and will ensure any biometric and genetic data is considered sensitive.

Consent

The data that we collect is subject to active consent by the data subject. This consent can be revoked at any time.

Criminal record checks

Any criminal record checks are justified by law. Criminal record checks cannot be undertaken based solely on the consent of the subject.

Data portability

Upon request, a data subject should have the right to receive a copy of their data in a structured format. These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This must be done for free.

Right to be forgotten

A data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.

Privacy by design and default

Privacy by design is an approach to projects that promote privacy and data protection compliance from the start. The DPO will be responsible for conducting Privacy Impact Assessments and ensuring that all recruitment projects commence with a privacy plan.

When relevant, and when it does not have a negative impact on the data subject, privacy settings will be set to the most private by default.

International data transfers

The DPO is to be made aware of all international data transfers

Data audit and register

Regular data audits to manage and mitigate risks will inform the data register. This contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant.

Reporting breaches

All members of staff have an obligation to report actual or potential data protection compliance failures. This allows us to:

  • Investigate the failure and take remedial steps if necessary
  • Maintain a register of compliance failures

Monitoring

Everyone must observe this policy. The DPO has overall responsibility for this policy. He will monitor it regularly to make sure it is being adhered to.

Consequences of failing to comply

We take compliance with this policy very seriously. Failure to comply puts both you and the organisation at risk.

The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in dismissal. A solicitor in breach of Data Protection responsibility under the law or the Code of Conduct may be struck off.

If you have any questions or concerns about anything in this policy, do not hesitate to contact the DPO.

Chris Slay

Managing Director

Skills Provision Limited