Dragons Teaching needs to gather and use certain information about individuals. These 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.
This data protection policy ensures Dragons Teaching:
- Complies with data protection law and follows good practice
- Protects the rights of staff, clients, students and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of a data breach
DATA PROTECTION LAW
The Data Protection Act 1998 describes how organisations — including Dragons Teaching – 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
Dragons Teaching will ensure that all clients, staff, students and partners who are the focus of the personal data (data subjects), are informed of the identity of the data controller; they will also be informed of the purposes of the processing, they will be given an indication of the period for which the data will be kept, and any other information which may be relevant or required.
2. Be obtained only for specific, lawful purposes
Dragons Teaching will ensure that the data collected from its clients, staff, students and partners is only used for the original reason of the collection of the data, unless the client or individual is informed of any additional processing before it takes place.
3. Be adequate, relevant and not excessive
Dragons Teaching will not collect any personal data which is not strictly necessary for the purpose for which it was obtained. Forms for collecting data will always be drafted with this in mind. If any irrelevant data is given to Dragons Teaching by clients or individuals, they will be destroyed immediately.
4. Be accurate and kept up to date
Dragons Teaching will review and update all data collected by clients, students and partners on a regular basis. It is the responsibility of our clients and individuals giving their personal data to ensure that this is accurate. Clients, students, parent/guardian and or partners should notify Dragons Teaching if the data needs to be updated. Our clients are encouraged to contact us to ensure that all information sorted is correct and updated. It is the responsibility of Dragons Teaching to ensure that any notification regarding the change is noted and acted on.
5. Not be held for any longer than necessary
Dragons Teaching will not to retain personal data for longer than is necessary to ensure compliance with the legislation, and any other statutory requirements. This means Dragons Teaching will undertake a regular review of the information held and will destroy any personal data collected that is no longer required. Dragons Teaching will dispose of any personal data in a way that protects the rights and privacy of the individual concerned (e.g. secure electronic deletion, shredding and disposal of hard copy files as confidential waste).
6. Processed in accordance with the rights of data subjects
Dragons Teaching will only process personal data in accordance with individuals’ rights.
7. Be protected in appropriate ways
All members of staff are responsible for ensuring that any personal data which they hold is kept securely and not disclosed to any unauthorised third parties. Dragons Teaching will ensure that all personal data is accessible only to those who have a valid reason for using it. Dragons Teaching will have appropriate security measures in place for the protection of any and personal data kept.
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
Dragons Teaching will not transfer data to such territories without the explicit consent of the individual. This also applies to publishing information on the Internet; because transfer of data can include placing data on a website that can be accessed from outside the EEA, Dragons Teaching will always seek the consent of individuals before placing any personal data (including photographs) on its website. If Dragons Teaching collects personal data in any form via its website, it will provide a clear and detailed privacy statement prominently on the website, and wherever else personal data is collected.
This policy applies to:
- The head office of Dragons Teaching
- All staff and volunteers of Dragons Teaching
- All contractors, suppliers and other people working on behalf of Dragons Teaching.
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:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Dates of Birth
- Any other information relating to clients or individuals.
DATA PROTECTION RISKS
This policy helps to protect Dragons Teaching 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 Dragons Teaching 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.
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.
- Dragons Teaching 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.
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 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.
Personal data is of no value to Dragons Teaching 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 Dragons Teaching 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 Dragons Teaching 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.
- Dragons Teaching will make it easy for data subjects to update the information Dragons Teaching 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.
SUBJECT ACCESS REQUESTS
All individuals who are the subject of personal data held by Dragons Teaching 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. Each request will be charged at £20+vat per request. Subject access requests from individuals should be made by email, addressed to the data controller at email@example.com. The data controller will aim to provide the relevant 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, Dragons Teaching 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.
Dragons Teaching 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.