This is the Data Protection Policy for Sundry Supplies Ltd.
During normal business activities, Sundry Supplies Ltd collects stores and processes a variety of types of personal information. Sundry Supplies Ltd recognizes the need to treat such information in a secure and lawful manner.
Sundry Supplies Ltd is committed to conducting its business in accordance with all applicable Data Protection laws and regulations, being transparent about how it collects and uses the personal data of its customers and clients, and to meeting its data protection obligations. This policy sets out Sundry Supplies Ltd's commitment to data protection and individual rights and obligations in relation to personal data.
Sundry Supplies Ltd has appointed Nicola Murray, Head of Information Security, as the person with responsibility for data protection compliance within Sundry Supplies Ltd. She can be contacted at firstname.lastname@example.org Questions about this policy, or requests for further information should be directed to her.
“Personal data” is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing, or destroying it.
“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and biometric data.
“Criminal records data” means information about an individual’s criminal convictions and offenses, and information relating to criminal allegations and proceedings.
Data Protection Principles
Sundry Supplies Ltd will process personal data in accordance with the following data protection principles:
- personal data will be processed lawfully, fairly, and in a transparent manner;
· personal data will be collected only for specified, explicit, and legitimate purposes;
· personal data will be processed only where it is adequate, relevant, and limited to what is necessary for the purposes of processing;
- personal data records will be kept accurate and up to date and all reasonable steps will be
taken to ensure that inaccurate personal data is rectified or deleted without delay;
· personal data will be retained only for the period necessary for processing. The periods for which Sundry Supplies Ltd holds personal data are contained in their privacy notices to individuals.
- appropriate measures will be adopted to make sure that personal data is secure, and protected against unauthorized or unlawful processing, and accidental loss, destruction, or damage.
Sundry Supplies Ltd will inform individuals of the reasons for processing their personal data, how it uses such data, and the legal basis for processing via its privacy notices. It will not process the personal data of individuals for other reasons.
Sundry Supplies Ltd keeps a record of its processing activities in respect of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).
Subject Access Requests
Individuals have the right to make a subject access request. If an individual makes a subject access request, Sundry Supplies Ltd will tell him/her:
· whether his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
· to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
· for how long his/her personal data is stored (or how that period is decided);
· his/her rights to rectification or erasure of data, or to restrict or object to processing;
· his/her right to complain to the Information Commissioner if he/she thinks Sundry Supplies Ltd has failed to comply with his/her data protection rights;
· whether Sundry Supplies Ltd carries out automated decision-making and the logic involved in any such decision-making.
Sundry Supplies Ltd will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically unless he/she agrees otherwise.
To make a subject access request, the individual should contact Nicola Murray at the email address on the front page of this document. In some cases, Sundry Supplies Ltd may need to ask for proof of identification before the request can be processed. Sundry Supplies Ltd will inform the individual if it needs to verify his/her identity and the documents it requires.
Sundry Supplies Ltd will respond to a request in accordance with the timelines set out in the DPA.
If a subject access request is manifestly unfounded or excessive, Sundry Supplies Ltd is not obliged to comply with it or may comply with it subject to some restrictions if permitted.
If an individual submits a request that is unfounded or excessive, Sundry Supplies Ltd will notify him/her that this is the case and whether it will respond to it.
Other Individual Rights
Individuals have other rights in relation to their personal data. They can require Sundry Supplies Ltd to:
- rectify inaccurate data;
- stop processing or erase data that is no longer necessary for the purposes of processing;
- stop processing or erase data if the individual’s interests override Sundry Supplies Ltd's legitimate grounds for processing data (where Sundry Supplies Ltd relies on its legitimate interests as a reason for processing data);
- stop processing or erase data if the processing is unlawful;
- stop processing data for a period if data is inaccurate or if there is a dispute about whether the individual’s interests override Sundry Supplies Ltd's legitimate grounds for processing data.
To ask Sundry Supplies Ltd to take any of these steps, the individual should contact the Head of Information Security.
Data subjects with a complaint about the processing of their personal data should put forward the matter in writing to the Head of Information Security. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case. The Head of Information Security will inform the data subject of the progress and the outcome of the complaint within a reasonable period. If the issue cannot be resolved through consultation between the data subject and the Head of Information Security, then the data subject may, at their option, seek redress through mediation, binding arbitration, litigation, or via complaint to the Data Protection Authority within the DPA.
Sundry Supplies Ltd takes the security of personal data seriously. Each Sundry Supplies Ltd business will adopt physical, technical, and organizational measures to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.
Where Sundry Supplies Ltd engages third parties to process personal data on their behalf, such parties do so based on written instructions, are under a duty of confidentiality, and are obliged to implement appropriate technical and organizational measures to ensure the security of data in line with prevailing data protection legislation and guidance from the Information Commissioner.
Sundry Supplies Ltd Entity will enter into an adequate processing agreement with the third party. The agreement must require the data processor to protect the personal data from further disclosure and to only process personal data in compliance with Sundry Supplies Ltd instructions. In addition, the data processor will be required to implement appropriate technical and organizational measures to protect the personal data, procedures for providing notification of personal data breaches, and submit to audits and inspections by the data controller. Sundry Supplies Ltd will maintain a list of any sub-processors which shall be available upon request.
Some of the processing that Sundry Supplies Ltd carries out may result in risks to privacy. Where processing would result in a high risk to an individual’s rights and freedoms, Sundry Supplies Ltd will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals, and the measures that can be put in place to mitigate those risks.
A personal data breach means a breach of security leading to the destruction, loss, alteration, unauthorized disclosure of, or access to, personal data. If Sundry Supplies Ltd discovers that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. Sundry Supplies Ltd will record all data breaches regardless of their effect.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.
International Data Transfers
Personal data may be transferred to countries outside the EEA. Data is transferred outside the EEA based where the organization receiving the personal data has provided adequate safeguards in accordance with all applicable Data Protection laws and regulations. Adequate safeguards mean the use of European Communities Model Clauses for transfers of personal data outside the EEA.
Individuals are responsible for helping Sundry Supplies Ltd keep their personal data up to date. Individuals should let Sundry Supplies Ltd know if data provided to Sundry Supplies Ltd changes, for example, if individual moves to a new house or changes his/her bank details.
The Head of Information Security is responsible for the maintenance and accuracy of this policy. It will be reviewed and updated at least annually, in response to a specific incident or when legislative requirements have changed. All changes to this policy are approved by Sundry Supplies Ltd Management. This policy shall be available to all Sundry Supplies Ltd employees through the Sundry Supplies Ltd internal drive.