The Fairer Parking Scheme needs to gather and use certain information about individuals.
These individuals can be customers, suppliers, business contacts, employees and other people the business has a relationship with, or may need to contact in the course of business.
This Policy describes how this personal data must be collected, handled and stored to meet the Group’s data protection standards and to comply with the law.
Adherence to the Fairer Parking Scheme Data Protection Policy applies to all permanent and contract staff, as well as the Directors of the business.
Aim of the Policy- This data protection policy ensures that the Fairer Parking Scheme:
- Complies with Data Protection Law
- Follows good practice at all times
- Protects the rights of staff, customers and partners
- Is open about the storage and processing of individual’s data
- Is protected from the risks of data breach
Data protection Law
The Data Protection Act 1988 describes how organisations 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 state that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside of the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.
This Policy Applies to:
- All Staff working for the Fairer Parking Scheme in any capacity.
- All contractors, suppliers and Third Parties working on behalf of the Fairer Parking Scheme.
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the DPA (1998). This can include:
- Names of individuals
- Telephone Numbers
- Postal Addresses
- Email Addresses
- And any other information relating to an individual
Data Protection Risks
This policy helps to protect the Fairer Parking Scheme from some very real data security risks, including:
- Breaches of confidentiality – For example, information being given out / disclosed 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 a loss of reputation and business if sensitive data is lost or stolen.
Everyone who works for or on behalf of the Fairer Parking Scheme has responsibility for ensuring data is collected, stored and handled appropriately.
Each person that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
The following people have key areas of responsibility.
The Board of Directors is ultimately responsible for ensuring that the Fairer Parking Scheme meets its legal obligations.
The Data Protection Officer, who is responsible for:
- Keeping the Board updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging Data Protection training and advice for the people covered by this policy.
- Handling Data Protection questions from staff and individuals covered by this policy.
- Dealing with subject access requests – i.e. requests from individuals to see the data the Group holds about them.
- Checking and approving any contracts or agreements with Third Parties that may handle the Groups sensitive data.
The IT Manager, is responsible for:
- Ensuring that all Third Parties that maintain systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks to ensure the policy is being adhered to across the group.
- Ensuring that the Third Parties that maintain the Group’s IT infrastructure are maintaining regular checks of security hardware and software. That it is in place, in latest version and running correctly.
- Evaluating any third Party services the Group is considering using to store or process data.
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 manager.
- The Fairer Parking Scheme 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 manager or the 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 Data Controller / IT Manager.
- 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 the purposes of completing specific work related tasks.
- When not required, the paper or files should be kept in a locked draw or filing cabinet.
- Employees should ensure paper and printouts are not left where unauthorised people could see them (for example, in tray, printer tray, side of a desk).
- 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 securely under lock and key when not in use.
- Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service.
- Servers containing personal data should be sited in a secure location, away from general office space.
- Data should be backed up frequently. Backups should be tested regularly in line with the Group’s back up procedures and Information Security Policy.
- Data should never be saved directly to laptops or other mobile devices (tablets / Smartphones)
- All Servers and computers containing data should be protected by approved security software and a firewall.
Data use
When personal data is accessed or 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 left unattended.
- Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
- 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 EEA
- Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
Data accuracy
The law requires the Fairer Parking Scheme to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort required to ensure its accuracy.
It is the responsibility of all employees who work with data to take 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 any unnecessary additional data sets.
Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
The Fairer Parking Scheme will make it easy for data subjects to update the information that the Fairer Parking Scheme holds about them.
Data 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 data base.
Subject access requests
All individuals who are the subject of personal data held by the Fairer Parking Scheme 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 the data controller at info@fairerparking.co.uk
- The data controller can supply a standard request form, although individuals do not have to use this.
- Individuals will be charged £10 per subject requests.
- 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, the Fairer Parking Scheme will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Providing information
The Fairer Parking Scheme 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.
A copy of the statement is attached in Appendix one.
Appendix one
The Fairer Parking Scheme Privacy Statement
Your privacy is important to the Fairer Parking Scheme. This privacy statement provides information about the personal information that the Fairer Parking Scheme collects, and the ways in which the Fairer Parking Scheme uses that personal information.
Personal information collection
Fairer Parking Scheme Limited may collect and use the following kinds of personal information:
- Your contact details (telephone, postal address and email) for the purposes of making contact with you to fulfil your order;
Using personal information
The Fairer Parking Scheme may use your personal information to:
- collect payments from you;
- Send to you products that you have ordered;
- supply to you services that you have requested;
- send to you statements, invoices and reminders;
Where the Fairer Parking Scheme discloses your personal information to its agents or sub-contractors for these purposes, the agent or sub-contractor in question will be obligated to use that personal information in accordance with the terms of this privacy statement.
In addition to the disclosures reasonably necessary for the purposes identified elsewhere above, the Fairer Parking Scheme may disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights.
Securing your data
The Fairer Parking Scheme will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
The Fairer Parking Scheme will store all the personal information you provide on its secure servers.
Cross-border data transfers
Information that the Fairer Parking Scheme collects may be stored and processed in and transferred between any of the countries in which the Fairer Parking Scheme operates to enable the use of the information in accordance with this privacy policy.
You agree to such cross-border transfers of personal information.
Updating this statement
The Fairer Parking Scheme may update this privacy policy by posting a new version on the Fairer Parking Scheme website (http://www.fairerparking.co.uk).
You should check this page occasionally to ensure you are familiar with any changes
Contact details
If you have any questions about this privacy policy or the Fairer Parking Scheme’s treatment of your personal information, please write:
- by email to info@fairerparking.co.uk