Data Protection Policy

1               ABOUT THIS POLICY

(1) Why do we have a policy?

(a) As an Organisation we store and use information, including personal information (“data”), about clients and others such as employees, workers (staff), job applicants, contractors, suppliers and others with whom we deal or have contact with according to our business obligations. In this Policy, which applies to everyone in the organisation, we will explain how we

  • protect the data
  • meet our legal obligations including the Data Protection Act 2018 and GDPR (General Data Protection Regulations)
  • maintain the rights of individuals whose data we hold (“data subjects”)

(b) Our policy works on the basis of “Privacy by Design” which means that we develop data protection measures that meet the needs of our organisation and regularly review them.

(c) The date and version of this policy is shown in the header.

 (2) The importance of this policy

(a) Everyone who works for, or on behalf of, the organisation has some responsibility for ensuring data is collected, stored and handled appropriately, in line with this policy and the following policies –

  • IT Policy which deals with Internet Use, Monitoring and Emails, Password Control and Remote Access

A copy of these policies can be obtained from the Appointed Person

 (b) Any employee who fails to comply with our data protection policy is dealt with under our disciplinary procedure.

(3) Criminal Liability

(a) The law provides for a number of criminal offences which can be committed in relation to personal data. These include making it an offence to alter personal data to prevent disclosure where  a person has made a request exercising their data subject access right and they would have been entitled to receive information in response to that request.

(b)(i) Some of the offences (like the example above) apply not only to data controllers but to company directors and employees (including apprentices) and volunteers.

(ii) It is therefore vital that everyone in the organisation understands their responsibilities and obligations and contacts the Appointed Person to discuss any concerns or raise queries as soon as they arise and before processing any personal data.

 (4) Information Commissioners Office (ICO) Registration

As the law permits we are NOT registered with the ICO.

(5) Accompanying documents

We refer to the following documents in this policy which are located at the end of this policy:


Annex Document Name Document Description
Annex 1 Our Data Inventory Record of what data we hold and how and why we process it
Annex 2 Security Measures Details of our organisational and technical measures to implement the data protection principles
Annex 3 Individual Request Form A form which can be used by any individual data subject to exercise their personal data rights



(1) Data Controller

We are a data controller (we “decide the purposes and means” of any data processing”).

(2) Appointed Person

(a) This type of organisation does not need to appoint a Data Protection Officer. However we have an Appointed Person, who monitors and implements this policy to ensure that we comply with our obligations. Information at the end of this policy (section 14) includes how our Appointed Person can be contacted.

(b) The Appointed Person will offer guidance and assistance in respect of any aspect of data protection and is responsible for compliance. Our Appointed Person will also ensure that anyone working with us understands their personal responsibility to comply with this policy.

(c) The Appointed Person will also:

  • Inform and advise the organisation as a whole about how it complies with data protection laws
  • Monitor our compliance with data protection laws. This may include conducting audits, data protection impact assessments, supervising staff training and generally managing our internal data processes and activities
  • Be the initial point of contact regarding data protection for everybody in the organisation, individuals whose data we process and any supervisory authorities

(3) We may also use data processors in relation to personal data. Data processors are people or organisations who process data on our behalf and in accordance with our instructions. For example we may use a market research company as part of our organisation’s marketing development.

(4) Staff Training and awareness

  • All of our employees will undergo basic data protection awareness during their induction with us
  • Employees who will be dealing with personal data will also receive data protection training relevant to their role. Training will be in a variety of methods, including online training and “on the job” training from managers
  • Employee Training is recorded in each individual’s Employee Training Record
  • We will ask all suppliers, contractors and those with whom we work to confirm that the relevant people working with us have also received data protection training relevant to their respective roles

3               ABOUT DATA

(1) Data

Data (information) includes not only electronically stored information, but includes information written on paper and all records which form any part of our data “system”.  Our data inventory contains our record of

  • What personal data we hold (a basic description of the data)
  • The category of data (personal or special)
  • Whose data it is

Data can be:

(a) Personal data”means information which relates to a living person who can be identified from that data (a “data subject”) on its own, or when taken together with other information which is likely to come into our possession. It includes any expression of opinion about the person and an indication of the intentions of us or others, in respect of that person. It does not include anonymised data. Examples of personal data include:

  • Contact details (particularly name, address, telephone number and email address)
  • Identification information (including passport details, visa and immigration status, date and place of birth)
  • Billing information (particularly bank account numbers and information and tax information)

 (b) “Special Category personal data” refers to more sensitive types of personal data about an individual including their:

  • Racial or ethnic origin;
  • Political opinions;
  • Religious or philosophical beliefs;
  • Trade union membership;
  • Genetic or biometric data (where it is used for ID purposes);
  • Health;
  • Sex life and sexual orientation; and
  • Any criminal convictions and offences

(c) Non-personal information– will not identify a person but just helps us to use the information to improve our services by identifying, for example, information collected using our website by recording pages accessed and files downloaded to record how visitors to the website use it.

We may aggregate information which is anonymous and does not identify an individual. For example, we may aggregate information about where people live and their ages for marketing purposes.

This policy is primarily concerned with personal (including special category) information.

(2) How we collect data

(a) Direct Data

Most of the data we collect is obtained directly from data subjects through trade shows, our websites, our dealings with others, such as clients, staff and those with whom we work, as well as suppliers.

(b) Indirect data

Occasionally we may collect data indirectly, for example publicly available information. When we receive information about any individual from another source, then within a reasonable period of having obtained the data (a maximum of one month or our first communication or before the data is disclosed) we will let the data subject know

  • That we have personal data about them and what data categories it falls into
  • Where it came from

 4               WHAT IS DATA PROTECTION?

By law you can only process (collect, record, organise, use, disclose share etc) personal data (data which could identify a natural person), if you

  • Comply with the data protection principles and
  • Have a lawful basis to do so, which means you must satisfy at least one of the lawful bases which it lays down

 (1) Data Protection Principles

We agree with and adhere to the main principles laid out by law, so that personal data must:

  • Be processed fairly, lawfully and transparently
  • Be collected and processed only for specified, explicit and legitimate purposes
  • Be adequate, relevant and limited to what is necessary for the purposes for which it is processed
  • Be accurate and kept up to date. Any inaccurate data must be deleted or rectified without delay
  • Not be kept for longer than is necessary for the purposes for which it is processed
  • Be processed securely

We are accountable for these principles and must be able to show that we comply.

 (2) Lawful Basis

(a) For personal data, the lawful bases are:

  • Consent– the individual data subject consents to the processing of their personal data
  • Contractual– processing is necessary either to take steps towards entering into a contract or to enter into a contract with the individual data subject
  • Legal obligation– processing is necessary because you need to comply with a legal obligation
  • Vital interests– processing is necessary to protect the vital interests of either the individual data subject or another person
  • Public tasks– processing is necessary to perform a task carried out in the public interest or in the exercise of official authority vested in the organisation
  • Legitimate interests– processing is necessary for purposes of legitimate interests pursued by the organisation or a third party, exceptwhere such interests are overridden by the interests, rights or freedoms of the data subject

(b) For special categories of personal data, the lawful bases are:

  • Explicit consent– the individual data subject has given their explicit consent for the processing of their personal data (unless relying on that consent is prohibited by law)
  • Employment, social security or social protection laws– processing is necessary for carrying out those obligations
  • Vital interests– processing is necessary to protect the vital interests of the data subject or another person where the data subject is either physically or legally incapable of giving consent
  • Not for Profit – processing for certain not-for-profit organisations providedcriteria are met 
  • Public– processing relates to personal data manifestlymade public by the data subject
  • Legal matters
  • Public tasks
  • Public health
  • Archiving, research or statistical purposes– processing is necessary for archiving purposes in the public interest and provided criteria are met

Our data inventory at Annex 1 contains our record of

  • Why we process particular data  and
  • The lawful basis for processing

(3) Withdrawing Consent

(a) Consent must be as easy to withdraw as it is to give (and without suffering any detriment unless consent is necessary for the service provided) which means that we have to provide information about how to do this. Examples of how consent can be withdrawn include:

(b) We must take action as soon as is possible and within no longer than 7 days when someone withdraws their consent and we have a set procedure for dealing with this.

(c) Any staff member may receive a withdrawal of consent and they must

  • If necessary (for example if consent is withdrawn during a telephone call), clarify the individual data subject’s full name and otherwise identify them so we can be sure we are dealing with the correct person (the relevant details)
  • Not deal with the withdrawal themselves unless that staff member has been specifically authorised and trained to do so and
  • Pass details about the request to their line manager or the Appointed Person by emailing them during the same day that the withdrawal is received, either attaching a copy of any written withdrawal and/or providing the relevant details


(1) Using data

(a) Our Organisation needs to process data for its business purposes and where the law says there are limited and justifiable circumstances. Processing should always be “fair, lawful and transparent”.

(b) Processing means any operation which is performed on personal data, including data which is part of a filing system and any automated processing. Processing includes

  • Collection, recording, organising, structuring or storing
  • Adapting or altering
  • Retrieval, consultation or use
  • Disclosure by transmission, dissemination or otherwise making available;
  • Alignment or combining
  • Restricting, erasing or destroying

(c) Our business purposes include

  • Providing clients with our services and products
  • Complying with our business/professional regulations and the law (such as payroll)
  • Releasing information legitimately if we are required by law to do so – such as by Court Order
  • Generally managing our organisation and its business

Our data inventory at Annex 1 contains our record of

  • What personal data we hold (a basic description of the data)
  • The category of data (personal or special)
  • Whose data it is
  • When personal data is processed

(d) We do NOT use data for decisions which are solely taken on an automatic basis.

(2) Privacy Notices

It is important that every data subject receives essential and important information about how we collect and use personal data. We have provided

  • A privacy policy on any website which we own and/or operate. Any staff member will print and provide a paper copy of this to anyone who asks for one
  • A staff privacy policy which is available from the Appointed Person.

(3) Confidentiality

This section relates to the additional professional confidentiality obligations imposed on us.

(a) Most information which our clients supply to us is confidential, which means that we will not share/disclose it with anybody else until they have instructed us to do so or we have to release it by regulatory compliance, law or Court Order. So, for example, if we are instructed to share personal information with a third party, we will ask for the data subject’s written consent to do that. However, some authorities (such as HMRC) may examine our information if they have a right to do so.

(b) We will obtain consent for each person/organisation that we have been instructed to share data with.

(c) Outsourcing – as part of our business we may use external providers for services such as for administration support and pass information to them. However, we have confidentiality agreements in place with them which means that information will only be held by them to provide services to us.


Data security means that we do what we reasonably can to protect the personal data that we hold and ensure our security is in accordance with current legal requirements.

(1) Managing risk – Data Protection Impact Assessments (DPIA)

It is important that we assess risks involved when we process data and so there will be occasions when we conduct a Data Protection Impact Assessments (DPIA).

DPIAs allow us to both identify risks and resolve issues at the earliest stage. There are certain circumstances when we must carry out a DPIA, including when

  • We are using new technologies
  • The processing is likely to result in a “high risk to the rights and freedoms of individuals”

The Appointed Person has overall responsibility for the DPIA

(2) Security Measures

(a) Our appropriate security measures are based on the likely risks to data which we have identified, for example loss of data or unauthorised disclosure. We have implemented appropriate organisational (people and processes) and technical measures to effectively implement the data protection principles.

(b) Our data inventory contains our record of

  • Where data is located ‐ who holds the data and who can access it
  • What security controls are in place

(c) Our Security Measures at Annex 2 outline the appropriate organisational (people and processes) and technical measures we have implemented.

(d) Everyone must adhere to our data security procedures and will receive appropriate training. Any employee who fails to comply with our data protection policy is dealt with under our disciplinary procedure and such an event may mean termination.

7               INDIVIDUAL RIGHTS

(1) The law gives rights to each individual in respect of their personal data. The rights included are:

  • To be informed (see Privacy Notices in section 5(2) of this policy)
  • To access data (Subject Access) which includes to

– obtain confirmation as to whether personal data is processed

– be provided with further information about the processing

– access their (the data subject’s) data/obtain a copy of it

  • Rectification (correct inaccurateor incomplete data)
  • Erasure/be forgotten (we can’t use the data but may quarantine it so it’s not used unlawfully and we keep it in a separate list)
  • Restrict processing (limit what we can do with the data)
  • Data portability (so an individual can obtain and move, copy or transfer personal data easily)
  • To object to processing data (limited circumstances)
  • Those rights available when processing is carried out by automated means and profiling but this does not apply to us because we do not do this type of processing

(2) Although it does not have to be used we have an Individual Request Form (at Annex 3) which individual data subjects can use to exercise these rights and we have a set procedure for dealing with these requests. You can access this at

(3) Dealing with requests to exercise data rights

(a) Any staff member may receive a request from an individual data subject to exercise a data right, irrespective of whether it is on an Individual Request Form or not (for example, someone may ask on the phone or by email). The staff member will

  • Not deal with the request unless they have been specifically authorised and trained to do so
  • Pass details about the request to their line manager or the Appointed Person by emailing them during the same day that the request is received

(b) We deal with each request as soon as we are able and within one month of receipt. If there is going to be a delay in dealing with any request or there is a reason why we can’t comply with your request we will let the individual data subject know and explain why within one month of receiving their request. We must deal with even complex cases within 3 months.

(c) Individual data subjects have the right to lodge any data protection complaints with the ICO, who is the UK’s supervisory authority. They should visit for more information including how to access their helpline.


(1) Record keeping is an important part of our data protection because it demonstrates how much we value data security and is a vital part of our compliance with the law. We keep a record of our data processing activities, including recording:

  • The type of data processed and
  • The purposes for which it was used

In addition, data processors will be asked to keep a record about who instructed them to process special category data.

(2) Our criteria

We keep information about people

  • For as long as it is necessary for the purposes for which the personal data are processed
  • To enable us to comply with our legal obligations, for example for tax purposes

(3) Data Retention

Data Subject How long personal information/data is kept


Potential Clients We will retain personal information for up to 5 years from the date of our last contact.
Clients We will retain personal information for 7 years from the date that you ceased to be a client.
Suppliers We will retain personal information for 7 years from the date that you ceased to be a supplier.
Employees We will retain personal information for 7 years from the date that you ceased to be an employee.



(1)(a) A personal data breach is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

(b) Although we take great care with our data the law requires us to have a process in place should a problem occur. Therefore

(i) it is the responsibility of every member of staff who deals with personal data to be able to recognise a personal data breach.

(ii) if you become aware of an actual or potential breach of our data obligations you must

  • Take notes and keep any evidence of it AND
  • Report it to our Appointed Person, within 24 hours of the time of the actual, suspected or potential breach being identified

(c) Our Appointed Person will then determine what action must be taken, including whether the ICO must be notified.

(2) The Appointed Person will then take the necessary action to

(a) Fully investigate the issue.

(b) Take remedial action.

(c) Keep a record of the breach which will include

  • The facts relating to the personal data breach
  • The effects of the breach
  • The remedial action taken

(d) Report relevant breaches to the ICO without undue delay after being identified and, where feasible, not later than 72 hours after becoming aware of a breach so as to minimise the risk of damage. Unless it is not possible to do so at the time (in which case the information will be provided without undue delay) that information will include

  • The Appointed Person’s name and contact details
  • A description of the personal data breach including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned
  • A description of the likely consequences of the personal data breach;
  • A description of the measures which we’ve taken or propose to take to address the personal data breach, including, where appropriate, mitigating its possible adverse effects

(e) In cooperation with the ICO and/or any other relevant authorities (such as the police) and taking into account any guidance, directly notify any affected individual data subjects involved, without undue delay and as soon as is reasonably feasible (the ICO may still decide to do this directly), of the data breach to allow them to take the necessary precautions unless one of the following exemptions are met

(i) the breach is unlikely to result in a high risk for an individual’s rights and freedoms

(ii) there was appropriate organisation and technical protection (such as encrypted data) in place when the breach occurred

(iii) notification would equate to a disproportionate effort, when an alternative such as a public information campaign may mean the individual can effectively be informed

(e) Where the Appointed Person notifies the affected individual data subjects about the data breach they will also make recommendations to mitigate potential adverse effects.


(1) Types of data sharing

Sharing data can be because we want

  • Someone to process the data and we remain as the data controller (they are a data processor)
  • To share the data with another organisation so that we can both decide why and how the data we hold will be processed. In this relationship we will both be data controllers because we can both decide how the data will be processed

Before we share any data we always ensure that

  • We have a lawful basis to enable us to share the personal data
  • we can justify sharing the data

We also use a third party data-sharing checklist to record essential information when we are sharing data with a third party. The checklist is available from the Appointed Person.

(2) Who we share data with

Ourorganisationneeds to share personal data with various third parties including:

  • Third-parties who provide services to us
  • Service providers who perform functions on our behalf
  • Third-party data storage providers who process data on our behalf
  • Public authorities who make a lawful request, including to meet national security or law enforcement requirements

Lists of the third parties with whom we share data are available from the Appointed Person

(3) Data Protection measures we take when sharing data

We have written agreements with those third parties to ensure that they

  • Provide the same level of protection that the law requires and
  • Transfer the minimum data necessary and anonymise data wherever reasonably possible
  • Limit their use of the data to the specified services they provide on our behalf
  • Process data on our behalf in accordance with our joint legal obligations


(1) Sometimes it is necessary for organisations to transfer personal data outside the EEA and because some countries do not have the same level of data protection the law restricts the transfer of personal data so that this can only take place if

  • Certain conditions are met. For example
    • there is a list of approved countries which provide an adequate level of data protection
    • there is an obligation on us to ensure that appropriate safeguards are in place, such as the EU-US Privacy Shield where organisations self-certify that they meet the Shield standards
  • There is a derogation or exemption (such as the individual’s informed, compliant and valid consent or contractual performance which allows us to do this
  • It’s a one-off transfer which meets the relevant criteria

(2) We do send some personal data outside the EEA but transfers do not take place unless the Appointed Person has confirmed that we meet one of the exemptions or conditions which enable us to do so.


(1) Clients will be made aware of this policy and its main content when we reach an agreement to provide our services and products to them.

(2) Suppliers will be made aware of the policy at the time we enter into an agreement that they will supply to us.

(3) Staff will be made aware of the policy and its content during induction or other training.

(4) We will review this Policy at least every twelve months (or as and when we know that any important changes in the law or guidelines is coming) and, where possible, twelve weeks’ notice of any changes to the Policy will be given to staff and, as applicable, clients and suppliers.

(5) Suggestions about this Policy are welcome. Please make suggestions to the Appointed Person.

13            COMPLAINTS

(1) Any queries or complaints regarding our data protection should be addressed to our Appointed Person, using the details at the end of this policy.

(2) Any individual can complain to a supervisory authority – currently the ICO. The ICO can be contacted via its website at is usually a live chat facility) or by using its telephone helpline on 0303 123 1113.

(3) Any individual data subject who wants to; obtain details about what personal information we hold about them; rectify data; restrict or object to processing; as from 25thMay 2018exercise the right to erasure, must contact our Appointed Person using the details at the end of this policy – please also see section 7 of this policy.


Appointed Person:Chris Brookman


By Post:7 Tuns Lane, Silverton, Exeter, Devon. EX5 4HY

By telephone:01392 861763


Please download our data inventory by clicking here.


This contains details of our organisational and technical measures to effectively implement the data protection principles.

  • Physical Security – including securing documents in locked cabinets when not in use and shredding confidential waste
  • Data backup – hourly to our own hard drives, all only password accessible. include detailsof encryption standard, password access protocols, remote storage and frequency
  • User access control management. We restrict access on a “need to know basis”.
  • Password control
  • Regular software updates in accordance with the recommended guidelines, if appropriate, by using patch management software
  • Timely decommissioning and secure wiping (that renders data unrecoverable) of old software and hardware
  • Encryption of all portable devices
  • Encryption of personal data in transit (e.g. SSL)
  • Secure configuration implemented on all devices (including mobile phones)
  • Providing internal policies, procedures and training including about IT Use (such as emails, internet and social media)
  • Regular reviews of the way we process data in line with our data protection policies


This is an option for which individual data subjects who want to exercise any of their legal rights in respect of their personal data can use.

Please download the form by clicking here.