Data Protection & Business Privacy Policy (GDPR)

Key details:

  • Policy prepared by: Tim Clixby
  • Approved by board / management on: 20th May 2018
  • Policy became operational on: 25th May 2018
  • Policy last reviewed on: 31st May 2024
  • Next review date: 31st May 2025

Introduction

Heatons Group Ltd 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 company’s data protection standards — and to comply with the law.

Why this policy exists.

This data protection policy ensures Heatons Group Ltd:

  • 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 individuals’ data
  • Protects itself from the risks of a data breach

The Data Protection Act 1998 describes how organisations — including Heatons Group Ltd — 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

Policy scope
This policy applies to:

  • The head office of Heatons Group Ltd
  • All branches of Heatons Group Ltd
  • All staff and volunteers of Heatons Group Ltd
  • All contractors, suppliers and other people working on behalf of Heatons Group Ltd
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:

  • 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 individuals’ data
  • Protects itself from the risks of a data breach

This policy helps to protect Heatons Group Ltd 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.

Everyone who works for or with Heatons Group Ltd has some responsibility for ensuring data is collected, stored and handled appropriately. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles. However, these people have key areas of responsibility:

    • The board of directors is ultimately responsible for ensuring that Heatons Group Ltd meets its legal obligations.


    • The data protection officer, Jackie Meachen, 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 anyone else covered by this policy.
      • Dealing with requests from individuals to see the data Heatons Group Ltd 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.


    • The ICT Director, Tim Clixby, is responsible for:
      • 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.
      • Handling data protection questions from staff and anyone else covered by this policy.


  • The Commercial Director, Danny Young, is responsible for:
    • Approving any data protection statements attached to communications such as emails and letters.
    • Addressing any data protection queries from journalists or media outlets like newspapers.
    • Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

  • 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.
  • Heatons Group Ltd 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 the data protection officer if they are unsure about any aspect of data protection.

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 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 USB Flash Drive, 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, away from general office space.
  • 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.
  • All servers and computers containing data should be protected by approved security software and a firewall.

We process personal information for certain legitimate business purposes, which inclide some or all of the following:

    • Where the processing enbables us to enhance, modify, personalised or otherwise improve our services / communications for the benefit of our customers.
    • To identify and prevent fraud.
    • To enhance the security of our networks and information systems.
    • To better understand how people interact with our websites.
    • To provide communications which we believe will be on interest to you.
    • To determine the effictiveness of promotional campaigns and advertising.

    Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regards and take account of these rights. You have the right to object to this processing if you wish and if you wish to do so please contact us. Please bear in mind that if you object, this may affect our ability to carr out tasks above for your benefit.

Personal data is of no value to Heatons Group Ltd 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 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 European Economic Area.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

The law requires Heatons Group Ltd 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 Heatons Group Ltd should put into ensuring 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.
  • Heatons Group Ltd will make it easy for data subjects to update the information Heatons Group Ltd holds about them. For instance, via the company website.
  • 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 database.
  • It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Under the Data Protection legislation, data subjects have the following rights with regards to their personal information:

  • the right to be informed about the collection and the use of their personal data
  • the right to access personal data and supplementary information
  • the right to have inaccurate personal data rectified, or completed if it is incomplete
  • the right to erasure (to be forgotten) in certain circumstances
  • the right to restrict processing in certain circumstances
  • the right to data portability, which allows the data subject to obtain and reuse their personal data for their own purposes across different services
  • the right to object to processing in certain circumstances
  • rights in relation to automated decision making and profiling
  • the right to withdraw consent at any time (where relevant)
  • the right to complain to the Information Commissioner
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 sales@heatons.net. The data controller can supply a standard request form, although individuals do not have to use this.
The data controller will aim to provide the relevant data within 30 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.

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, Heatons Group Ltd 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.

Heatons Group Ltd 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.
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