Privacy Policy

Rationale

Herongrange Ltd (HERONGRANGE LTD) is committed to a policy of protecting the rights and privacy of individuals, including learners, staff and others, in accordance with the General Data Protection Regulation (GDPR) May 2018. The new regulatory environment demands higher transparency and accountability
in how companies manage and use personal data. It also accords new and stronger rights for individuals to understand and control that use.

The GDPR contains provisions that the company will need to be aware of as data controllers, including provisions intended to enhance the protection of employees personal data. For example, the GDPR requires that:

We must ensure that our company privacy notices are written in a clear, plain way
that staff and employees will understand. HERONGRANGE LTD needs to process certain information about its staff, employees and other individuals with whom it has a relationship for various purposes such as, but not limited to:

1. The recruitment and payment of staff.
2. Recording employee progress, attendance and conduct.
3. Complying with legal obligations to government bodies

To comply with various legal obligations, including the obligations imposed on it by
the General Data Protection Regulation (GDPR) HERONGRANGE LTD must ensure that all this
information about individuals is collected and used fairly, stored safely and securely,
and not disclosed to any third party unlawfully.

Compliance

This policy applies to all staff and employees of HERONGRANGE LTD. Any breach of this policy or of the regulation itself will be considered an offence and the Company’s disciplinary procedures will be invoked. As a matter of best practice, other agencies, sub-contractors and individuals working with HERONGRANGE LTD and who have access to personal information, will be expected to read and comply with this policy. It is expected that departments who are responsible for dealing with external bodies or sub-contractors will take the responsibility for ensuring that they sign a contract which among other things will include an agreement to abide by this policy. This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments to the GDPR and other relevant legislation.

General Data Protection Regulation (GDPR) This piece of legislation came in to force on the 25 th May 2018. The GDPR regulates the processing of personal data, and protects the rights and privacy of all living individuals (including children), for example by giving all individuals who are the subject of personal data a general right of access to the personal data which relates to them. Individuals can exercise the right to gain access to their information by means of a ‘subject access request’. Personal data is information relating to an individual and may be in hard or soft copy (paper/manual files; electronic records; photographs; CCTV images), and may include facts or opinions about a person.

Responsibilities under GDPR

HERONGRANGE LTD will be the ‘data controller’ under the terms of the legislation – this means it is ultimately responsible for controlling the use and processing of the personal data.

The company may appoint a Data Protection Officer (DPO), if required. At this point, the data controller for HERONGRANGE LTD is Carlie Baxter, Director.
Carlie is responsible for all day-to-day data protection matters, and will be responsible for ensuring that all members of staff and relevant individuals abide by this policy, and for developing and encouraging good information handling within the company. Compliance with the legislation is the personal responsibility of all members of the Company who process personal information. Individuals who provide personal data to the Company are responsible for ensuring that the information is accurate and up-to-date.

Data Protection Principles

The legislation places a responsibility on every data controller to process any personal data in accordance with the eight principles
In order to comply with its obligations, HERONGRANGE LTD undertakes to adhere to the eight
principles:

1) Process personal data fairly and lawfully.
HERONGRANGE LTD will make all reasonable efforts to ensure that individuals who are the focus of the personal data (data subjects) are informed of the identity of the data controller, the purposes of the processing, any disclosures to third parties that are envisaged; given an indication of the period for which the data will be kept, and any other information which may be relevant.

2) Process the data for the specific and lawful purpose for which it collected that
data and not further process the data in a manner incompatible with this
purpose.
HERONGRANGE LTD will ensure that the reason for which it collected the data originally is the only reason for which it processes those data, unless the individual is informed of any additional processing before it takes place.

3) Ensure that the data is adequate, relevant and not excessive in relation to the
purpose for which it is processed.
HERONGRANGE LTD will not seek to 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 mind. If any irrelevant data are given by individuals, they will be destroyed immediately.

4) Keep personal data accurate and, where necessary, up to date.
HERONGRANGE LTD will review and update all data on a regular basis. Annually at least. It is the responsibility of the individuals giving their personal data to ensure that this is accurate, and each individual should notify the Company if, for example, a change in circumstances mean that the data needs to be updated. It is the responsibility of the Company to ensure that any notification regarding the change is noted and acted on.

5) Only keep personal data for as long as is necessary.
HERONGRANGE LTD undertakes not to retain personal data for longer than is necessary to ensure compliance with the legislation, and any other statutory requirements. This means HERONGRANGE LTD 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).

6) Process personal data in accordance with the rights of the data subject under the legislation.
Individuals have various rights under the legislation including a right to:

  • be told the nature of the information the Company holds and any parties to whom this may be disclosed.
  • prevent processing likely to cause damage or distress.
  • prevent processing for purposes of direct marketing.
  • be informed about the mechanics of any automated decision taking process that will significantly affect them.
  • take action to rectify, block, erase or destroy inaccurate data.
  • HERONGRANGE LTD will only process personal data in accordance with individuals’ rights.

7) Put appropriate organisational measures in place against unauthorised or unlawful processing of personal data, and against accidental loss or destruction of data.
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.
HERONGRANGE LTD will ensure that all personal data is accessible only to those who have a valid reason for using it. HERONGRANGE LTD will have in place appropriate security measures e.g. ensuring that hard copy personal data is kept in lockable filing cabinets/cupboards with controlled access (with the keys then held securely in a key cabinet with controlled access):

  • keeping all personal data in a lockable cabinet with key-controlled access.
  • password protecting personal data held electronically.
  • archiving personal data which are then kept securely (lockable cabinet).
  • placing any PCs or terminals, CCTV camera screens etc. that show personal data so that they are not visible except to authorised staff.
  • ensuring that PC screens are not left unattended without a password protected screen-saver being used.

In addition, HERONGRANGE LTD will put in place appropriate measures for the deletion of personal data – manual records will be shredded or disposed of as ‘confidential waste’ and appropriate contract terms will be put in place with any third parties undertaking this work. Hard drives of redundant PCs will be wiped clean before disposal or if that is not possible, destroyed physically. This policy also applies to staff and employees who process personal data ‘off-site’, e.g.
when working at home, and in circumstances additional care must be taken regarding the security of the data, e.g checking emails on phone or mobile devices.

8) Ensure that no personal data is transferred to a country or a territory outside the European Economic Area (EEA) unless that country or territory ensures adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
HERONGRANGE LTD 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 – so HERONGRANGE LTD will always seek the consent of individuals before placing any personal data (including photographs) on its website and social media. If the Company 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.

Consent as a basis for processing

Although it is not always necessary to gain consent from individuals before processing their data, it is often the best way to ensure that data is collected and processed in an open and transparent manner. Consent is especially important when HERONGRANGE LTD is processing any sensitive data, as
defined by the legislation.

Subject Access Rights (SARs)

Individuals have a right to access any personal data relating to them which are held by the Company. Any individual wishing to exercise this right should apply in writing to the Director(s). Any member of staff receiving a SAR should forward this to the Director(s)
Under the terms of the legislation, any such requests must be complied with within 40days.

Disclosure of Data

Only disclosures which have been notified under the Company’s DP notification must be made and therefore staff and employees should exercise caution when asked to disclose personal data held on another individual or third party.
HERONGRANGE LTD undertakes not to disclose personal data to unauthorised third parties, including family members, friends, and in some circumstances, the police or HSE.
Legitimate disclosures may occur in the following instances:

  • the individual has given their consent to the disclosure.
  • the disclosure is in the legitimate interests of the Company.
  • the disclosure is required for the performance of a contract.

There are other instances when the legislation permits disclosure without the consent
of the individual.

In no circumstances will HERONGRANGE LTD sell any of its databases to a third party.

Publication of Company Information

HERONGRANGE LTD publishes various items which will include some personal data, e.g.

  • internal telephone directory.
  • event information.
  • photos and information in marketing materials.

It may be that in some circumstances an individual wishes their data processed for such reasons to be kept confidential, or restricted Company access only. Therefore it is HERONGRANGE LTD policy to offer an opportunity to opt-out of the publication of such when collecting the information.
Email
It is the policy of HERONGRANGE LTD to ensure that senders and recipients of email are made aware
that under the DPA, and Freedom of Information Legislation, the contents of email may have to be disclosed in response to a request for information. One means by which this will be communicated will be by a disclaimer on the Company’s email.
CCTV
There are some CCTV systems operating within HERONGRANGE LTD for the purpose of protecting Company members and property. HERONGRANGE LTD will only process personal data obtained by the CCTV system in a manner which ensures compliance with the legislation.

Procedure for review

This policy will be updated as necessary to reflect best practice or future amendments made to the General Data Protection Regulation (GDPR) May 2018 and Data Protection Act 1998.

Please follow this link to the ICO’s website (www.ico.gov.uk) which provides further detailed guidance on a range of topics including individuals’ rights, exemptions from the Act, dealing with subject access requests, how to handle requests from third parties for personal data to be disclosed etc. In particular, you may find it helpful to read the Guide to Data Protection which is available from the website. For help or advice on any data protection or freedom of information issues, please do not hesitate to contact:
Carlie Baxter
Company Director

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