Data Protection Policy

Key details:

• This policy has been prepared by: Nadin Dunnigan
• This policy became operational on: 16 April 2018
• Next review date: 31 October 2018

Introduction

Nadin Dunnigan Photography Ltd needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, 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 that Nadin Dunnigan Photography Ltd:

• Complies with data protection law and follow good practice
• Protects the rights of 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 GDPR describes how organisations — including Nadin Dunnigan Photography Ltd— 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 GDPR is underpinned by eight important principles. These say that personal data must:

• Be processed fairly and lawfully 
• Be obtained only for specific, lawful purposes 
• Be adequate, relevant and not excessive 
• Be accurate and kept up to date 
• Not be held for any longer than necessary 
• Processed in accordance with the rights of data subjects 
• Be protected in appropriate ways 
• Not 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 Nadin Dunnigan Photography Ltd
• All branches of Nadin Dunnigan Photography Ltd (also trading as Business Image (web design services)
• All staff and volunteers of Nadin Dunnigan Photography Ltd
• All contractors, suppliers and other people working on behalf of Nadin Dunnigan Photography Ltd

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• …plus any other information relating to individuals (such as wedding date)

Data protection risks

This policy helps to protect Nadin Dunnigan Photography Ltd 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 Nadin Dunnigan Photography Ltd has some responsibility for ensuring data is collected, stored and handled appropriately. Whomever at Nadin Dunnigan Photography Ltd 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:

Nadin Dunnigan is ultimately responsible for ensuring that Nadin Dunnigan Photography Ltd meets its legal obligations. Nadin Dunnigan is responsible for: 

• Keeping  updated about data protection responsibilities, risks and issues. 
• 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 Nadin Dunnigan Photography Ltd holds 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. 

Nadin Dunnigan is responsible for IT used at Nadin Dunnigan Photography Ltd, including computers, laptops, mobile phones and other devices that can store personal data. Nadin Dunnigan will ensure

• that 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. 

Nadin Dunnigan is responsible for any marketing related activities at Nadin Dunnigan Photography Ltd. Nadin is responsible for:

• Approving any data protection statements attached to communications such as emails and letters. 
• Addressing any data protection queries from journalists or media outlets like newspapers. 
• Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General guidelines for data usage

• 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, it can be request from Nadin Dunnigan.
• Nadin Dunnigan Photography Ltd will request that suppliers understand their responsibilities when handling data.
• 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.

Data storage

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 or access 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. Nadin will 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 USB or external disk), 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.

Data use

Personal data is of no value to Nadin Dunnigan Photography Ltd 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, Nadin Dunnigan will 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. 
• Personal data should never be transferred outside of the European Economic Area.
• Only central copies of any data will accessed and updates. There must not be multiple copies of personal data.

Data accuracy

The law requires Nadin Dunnigan Photography Ltd 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 Nadin Dunnigan Photography Ltd should put into ensuring its accuracy. Nadin Dunnigan is 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. Nadin Dunnigan should not create any unnecessary additional data sets. Nadin Dunnigan should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call. Nadin Dunnigan Photography Ltd will make it easy for data subjects to update the information Nadin Dunnigan Photography Ltd 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. It is the Nadin Dunnigan's responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject access requests

All individuals who are the subject of personal data held by Nadin Dunnigan Photography Ltd 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. 

Subject access requests from individuals should be made by email, using the below contact form. Enquiries sent through this form are sent directly  to Nadin Dunnigan. You can also call Nadin Dunnigan directly at 07834 826 500.

Individuals will be charged £10 per subject access request. Nadin Dunnigan will aim to provide the relevant data within 14 days.

Nadin Dunnigan 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 GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Nadin Dunnigan Photography Ltd 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.

Providing information

Nadin Dunnigan Photography Ltd 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.