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General Data Protection Policy

Context and overview

Key details
⦁    Policy prepared by: Dave Carnelly                
⦁    Approved by board / management on: 01 Jan 2021        
⦁    Policy became operational on: 01 Jan 2021              
⦁    Next review date: 31 Dec 2021          


Phototronics Ltd 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:
⦁    Complies with data protection law and follow 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 General Data Protection Regulation 2021 describes how organisations — including Phototronics 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.
To comply to GDPR, organisations broadly speaking need to embed six privacy principles within their operations:
1. Lawfulness, fairness and transparency
Transparency: Tell the subject what data processing will be done. Fair: What is processed must match up with how it has been described. Lawful: Processing must meet the tests described in GDPR [article 5, clause 1(a)].
2. Purpose limitations
Personal data can only be obtained for “specified, explicit and legitimate purposes”[article 5, clause 1(b)]. Data can only be used for a specific processing purpose that the subject has been made aware of and no other, without further consent.
3. Data minimisation 
Data collected on a subject should be “adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed” [article 5, clause 1(c)]. In other words, no more than the minimum amount of data should be kept for specific processing.
4. Accuracy
Data must be “accurate and where necessary kept up to date” [article 5, clause 1(d)]. Baselining ensures good protection and protection against identity theft. Data holders should build rectification processes into data management / archiving activities for subject data. 
5. Storage limitations
Regulator expects personal data is “kept in a form which permits identification of data subjects for no longer than necessary” [article 5, clause 1(e)]. In summary, data no longer required should be removed.

People, risks and responsibilities

Policy scope
This policy applies to:
⦁    The head office of Phototronics Ltd
⦁    All staff and volunteers of Phototronics Ltd
⦁    All contractors, suppliers and other people working on behalf of Phototronics Ltd
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the General Data Protection Act 2021. This can include:
⦁    Photographs
⦁    Names, school admission number, registration group of individuals
⦁    Postal addresses
⦁    Email addresses
⦁    Telephone numbers
⦁    …plus any other information relating to individuals

Data protection risks
This policy helps to protect Phototronics 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.

Everyone who works for or with Phototronics Ltd has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team 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 board of directors is ultimately responsible for ensuring that Phototronics Ltd meets its legal obligations.
⦁    The Data Protection Officer, Paul Price, is responsible for:
⦁    Keeping the board 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 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.
⦁    The ,IT contractors, ADT are responsible for:
⦁    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.
⦁    The ,Office Manager, Lorraine Thurston 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 staff 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.
⦁     Phototronics Ltd 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, unique 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
Phototronics Ltd collects and uses personal data to fulfil school requirements and prepare and deliver photographs. 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 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, 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 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.
⦁    Any information we collect regarding pupil information, should be and is encrypted in a zip file which will only be unencrypted by the person in sole charge of producing products for This employee is the only person to be entitled to requesting the said information.
⦁    Images are kept stored for 1 year and then removed.

Data use
Personal data is of no value to Phototronics 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, 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 IT manager can explain how to send data to authorised external contacts.
⦁    Personal data should never be transferred outside of the European Economic Area.
⦁    Employees will 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 Phototronics 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 Phototronics Ltd 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.
⦁    Phototronics Ltd will make it easy for data subjects to update the information Phototronics 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 marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

All employees and in particular photographers are enhanced DBS checked and these are updated as and when needed. All photographers carry DBS certificates with them at all times whilst on Phototronics Ltd official business. Copies of photographers DBS are kept in a locked filing cabinet in Head office and all DBS information is provided to all schools on an annual basis, this is in line with our current safeguarding procedure. Photographers do not carry with them Laptops or other portable memory devices other than the current CF (compact flash) being used for the job. Cameras will be kept with photographers at all times and the CF card is kept securely on their person until such a time that these images can be securely transferred to our internal server.

Data Merge information for schools databases
All data for any school database is kept on password protected computers in an alarmed office with external shutters and alarm which is serviced by Petch Protection Solutions Ltd The building also has internal CCTV in all data sensitive areas, this is maintained by Petch Protection Solutions Ltd. Information received by us is kept in an encrypted Zip file and only extracted at the time that the information is used to produce pre-printed shoot cards. The information on these cards is kept by the way of a bar code and can only be read via the camera and extracted once the image has been taken and has been run through software produced by HalSYS. This software is installed on one password protected computer.

Photograph Production and dispatch
Only authorised employees have access to any personal data in our lab located in our secure Head Office. All our images are produced internally and packed in the same building.

Online Orders
Phototronics Ltd online photograph orders are a bespoke system provided by HalSYS and GotPhoto. Images are stored securely on the relevant servers. 
Online orders can only be accessed by a person in receipt of a unique username and password. Passwords are randomly generated with letters and numbers in both upper and lower case giving xxxxxxxxx unique combinations.

Any Debit or credit card, cheque or cash payments that are handed in to school are collected securely by a Phototronics Ltd representative in a secure plain bag and return directly to our head office. Orders are then processed and Debit/Credit Card slips are kept in a locked safe for a period of 3 months when they are then securely destroyed. 

Subject access requests
All individuals who are the subject of personal data held by Phototronics 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, addressed to the data controller at 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 14 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, Phototronics 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
Phototronics 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.