Policy prepared by: Keepoint Ltd
Approved by Director on: 08 February 2018
Next review date: 07 February 2019
Data Protection Registration Number (ico.): Z3296701

GDPR Policy

Keepoint takes your privacy very seriously. We ask that you read this GDPR policy carefully as it contains important information about what to expect when we collect business/personal information about you and how we will use your business/personal data.

Introduction:

Keepoint 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 Keepoint:

  • Complies with data protection law and follows 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

Data protection law:

The Data Protection Act 1998 describes how organisations, including Keepoint, 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.

Keepoint ensure that personal information is:

  1. processed fairly and lawfully
  2. obtained only for specified, lawful purposes
  3. adequate, relevant and not excessive
  4. accurate and kept up to date
  5. not to be held for any longer than necessary
  6. processed in accordance with the rights of data subjects
  7. protected in appropriate ways
  8. not to be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.

People, risks and responsibilities:

Policy scope

This policy applies to:

  • The head office of Keepoint
  • All branches of Keepoint
  • All staff and volunteers of Keepoint
  • All contractors, suppliers and other people working on behalf of Keepoint

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
  • …plus any other information relating to individuals

Data protection risks

This policy helps to protect Keepoint 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.

Responsibilities

Everyone who works for or with Keepoint has some responsibility for ensuring that data is collected, stored and handled appropriately.

Every employee 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 Director is ultimately responsible for ensuring that Keepoint meets its legal obligations.
  • The Director is responsible for:
    • 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 Keepoint hold 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.
    • 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.
    • Approving any data protection statements attached to communications such as emails and letters.
    • Addressing any data protection queries from other staff to ensure marketing initiatives abide by data protection principles.

General 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.
  • Keepoint 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.

Data storage:

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Director.

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 when 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 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.

Data Use:

Personal data is of no value to Keepoint 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 Director can explain how to send data to authorised external contacts.
  • 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 Keepoint 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 Keepoint 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.
  • Keepoint will make it easy for individuals to update the information Keepoint hold 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 database.

Subject access requests:

All individuals who are the subject of personal data held by Keepoint 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.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should ideally be made by email, addressed to the Director controller at Keepoint, Bulloch House, 10 Rumford Place, Liverpool, L3 9DG. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 40 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, Keepoint will disclose requested data. However, Keepoint will ensure the request is legitimate, seeking assistance from our legal advisers where necessary.

Providing information:

Keepoint 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.

What will your data be used for:

The personal information supplied by you may be recorded and processed by us for the following purposes:

• The provision of serviced and/or virtual offices and related services;

• To verify your identity; and

• To fight against crime, fraud, money laundering and terrorism.

The legal basis for processing your personal information in the ways described above will typically be

(i) to fulfil our obligations

(ii) for compliance with a legal obligation to which we are subject to or

(iii) for our legitimate business interests except where such interests are overridden by your interests and fundamental rights.

In order to carry out the above we will from time to time disclose your data to the following:

• Anyone who you authorise us to disclose information to;

• Other group companies of ours and our trading partners;

• Other organisations instructed by us to make background checks and enquiries about you as part of our due diligence;

• Any Government entity, regulatory authority or to any other person we reasonably think necessary for the purposes stated above; and

• The Business Centre Association and their members.

We will hold your information for as long as is reasonably necessary for the purposes listed above or as is required under applicable local law after which it will be destroyed.

Your rights:

Under data protection legislation you have certain rights in relation to your personal information. You may:

• Check whether we hold information about you;

• Ask to see a copy of the information we hold about you;

• Under certain circumstances:

o Ask us to rectify any inaccurate and/or complete any incomplete personal information we hold about you;

o Ask us to stop processing your personal information; or

o Ask us to provide certain of your personal information to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services.