
DATA PROTECTION POLICY
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Last updated November 2024.
The principles of data protection:
The Act stipulates that anyone processing personal data must comply with Eight Principles of good practice. These Principles are legally enforceable.
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The Principles require that personal information:
1. Shall be processed fairly and lawfully and in particular, shall not be processed unless specific conditions are met;
2. Shall be obtained only for one or more specified and lawful purposes and shall not be further processed in any manner incompatible with that purpose or those purposes;
3. Shall be adequate, relevant and not excessive in relation to the purpose or purposes for which it is processed;
4. Shall be accurate and where necessary, kept up to date;
5. Shall not be kept for longer than is necessary for that purpose or those purposes;
6. Shall be processed in accordance with the rights of data subjects under the Act;
7. Shall be kept secure i.e. protected by an appropriate degree of security;
8. Shall not be transferred to a country or territory outside the European Economic Area, unless that country or territory ensures an adequate level of data protection.
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The Act provides conditions for the processing of any personal data. It also makes a distinction between personal data and ”sensitive” personal data. Personal data is defined as, data relating to a living individual who can be identified from:
ï‚· That data;
ï‚· That data and other information which is in the possession of, or is likely to
come into the possession of the data controller and includes an expression of
opinion about the individual and any indication of the intentions of the data
controller, or any other person in respect of the individual.
Sensitive personal data is defined as personal data consisting of information as to:
ï‚· Racial or ethnic origin;
ï‚· Political opinion;
ï‚· Religious or other beliefs;
ï‚· Trade union membership;
ï‚· Physical or mental health or condition;
ï‚· Sexual life;
ï‚· Criminal proceedings or convictions.
Handling of personal/sensitive information Blue Ridge Designs will, through appropriate management and the
use of strict criteria and controls:-
ï‚· Observe fully conditions regarding the fair collection and use of personal information;
ï‚· Meet its legal obligations to specify the purpose for which information is used;
ï‚· Collect and process appropriate information and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements;
ï‚· Ensure the quality of information used;
ï‚· Apply strict checks to determine the length of time information is held;
ï‚· Take appropriate technical and organisational security measures to
safeguard personal information;
ï‚· Ensure that personal information is not transferred abroad without
suitable safeguards;
ï‚· Ensure that the rights of people about whom the information is held
can be fully exercised under the Act.
These include:
ï‚· The right to be informed that processing is being undertaken;
ï‚· The right of access to one’s personal information within the
statutory 40 days;
ï‚· The right to prevent processing in certain circumstances;
ï‚· The right to correct, rectify, block or erase information regarded as
wrong information.
In addition, Blue Ridge Designs will ensure that:
ï‚· There is someone with specific responsibility for data protection in the
organisation;
ï‚· Everyone managing and handling personal information understands
that they are contractually responsible for following good data
protection practice;
ï‚· Everyone managing and handling personal information is appropriately
trained to do so;
ï‚· Everyone managing and handling personal information is appropriately
supervised;
ï‚· Anyone wanting to make enquiries about handling personal
information, whether a member of staff or a member of the public,
knows what to do;
ï‚· Queries about handling personal information are promptly and
courteously dealt with;
ï‚· Methods of handling personal information are regularly assessed and
evaluated;
ï‚· Performance with handling personal information is regularly assessed
and evaluated;
ï‚· Data sharing is carried out under a written agreement, setting out the scope and limits of the sharing. Any disclosure of personal data will be in compliance with approved procedures.
Directors and employees will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure and in particular will ensure that:
ï‚· Paper files and other records or documents containing
personal/sensitive data are kept in a secure environment;
ï‚· Personal data held on computers and computer systems is protected
by the use of secure passwords, which where possible have forced
changes periodically;
ï‚· Individual passwords should be such that they are not easily compromised.
Notification to the Information Commissioner
The Data Protection Act 1998 requires every data controller who is processing personal data, to notify and renew their notification, on an annual basis. Failure to do so is a criminal offence. To this end the persons responsible for notifying and updating the Information Officer of the processing of personal data, within their directorate. The Information Officer will review the Data Protection Register with designated officers annually, prior to notification to the Information Commissioner. Any changes to the register must be notified to the Information Commissioner,
within 28 days. To this end, any changes made between reviews will be brought to the attention
of the Information Officer immediately.