Guiding Principles
● The Data Protection Act is the UK’s implementation of the General Data Protection Regulation (GDPR). The Data Protection Act 2018 and the General Data Protection Regulations outline the principles regarding collecting, handling and storing personal information.
● All staff (paid/unpaid) working in the organisation have a responsibility to uphold data protection law and follow the guidance stated in this policy.
Protection Policy Statement
Polaris Outdoor needs to gather and use certain information about individuals. We appreciate the trust placed in us to hold this data and understand the importance of keeping personal information safe. We will only use this information so we can communicate information to individuals about our programmes, support those who are participating, and to tell people about activities which may be of interest.
These individuals can include customers, suppliers, business contacts, staff 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 that the organisation:
● 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 and its 2018 update describe how organisations 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 “data protection principles”. These say that personal data must:
1. Be processed fairly, lawfully and transparently
2. Be obtained only for specific, explicit and lawful purposes
3. Be adequate, relevant and limited to only what is necessary
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in a way that ensures appropriate security, including protection against unlawful or unauthorised processing, access, loss, destruction or damage.
Policy scope
The aim of the Data Protection Policy is to promote good practice which ensures:
● The law is followed to try to prevent data security risks including breaches of confidentiality, failing to offer choice and reputational damage. No technology is fail-safe, but we have made every reasonable effort to update our systems with relevant protocols.
● The staff maintain data security through following procedures.
This policy applies to all staff, volunteers, contractors, suppliers and other people working on behalf of the organisation. Everyone who works for or with the organisation has some responsibility for ensuring data is collected, stored and handled appropriately.
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.
Promoting good practice
● The Organisation is registered with the Information Commissioner’s Office (ICO)
● Matthew Barnsley, Director, is the designated Data Protection Officer (DPO). Staff should request help from the company director if they are unsure about any aspect of data protection.
● 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.
● We provide training to all staff to help them understand their responsibilities when handling data.
● Staff should keep all data secure, by taking sensible precautions and following the guidelines.
● In particular, strong passwords must be used and they should never be shared.
● Personal data should not be disclosed to unauthorised people.
● 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 securely disposed of.
● This policy shall be reviewed at least annually in accordance with ICO and government updates.
● In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Polaris Outdoor will promptly assess the risk to people’s right and freedoms, and if appropriate report this breach to the ICO. An internal investigation will be completed to determine what could have been done to prevent the breach and for lessons to be learnt in order to prevent further or future issues.
Data storage
These rules describe how and where data should be safely stored.
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, such as 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:
o Data should be protected by strong passwords that are changed regularly and never shared between employees.
o If data is stored on removable media (like a memory device), these should be kept locked away securely when not being used.
o Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service.
o Servers containing personal data should be sited in a secure location.
• Data should be backed up frequently to the cloud storage.
• Data saved directly to laptops or other mobile devices like tablets or smart phones should be secured with a strong password or code.
• All computers containing data should be protected by approved security software.
Data use
Polaris Outdoor collects information on individual participants and their group leaders in order to fulfil its duties as a Provider of Outdoor Education. Data collected and used by Polaris Outdoor is outlined in the Data Held Table in Appendix 1 alongside the reasons for data capture and length of time data held.
Personal data is of no value 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.
• Data must be encrypted before being transferred electronically.
• Personal data should never be transferred to regions with lower levels of data protection.
• Employees should make sure that all files and correspondence are only accessed by the intended recipients.
Data accuracy
The law requires the organisation to take reasonable steps to ensure data is kept accurate and up to date.
It is the responsibility of all staff 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 take every opportunity to ensure data is updated.
● 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 the organisation 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, addressed to the director at info@polarisoutdoor.co.uk. We will aim to provide the relevant data within 30 days. It is necessary to 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, the organisation will disclose requested data. However, the directors will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Providing information – Privacy Statement
We will ensure that individuals are aware that their data is being processed, and that they understand:
● How the data is being used
● That the data is only used for the stated purpose
● That the data is held securely
● How to exercise their rights, access their data and make corrections