Policies/ gdpr

You must read this policy because it gives important information about: • the data protection principles with which the Company must comply. 

• what is meant by personal information (or data) and sensitive personal  information (or data); 

• how we gather, use and (ultimately) delete personal information and sensitive  personal information in accordance with the data protection principles. 

• where more detailed privacy information can be found, e.g., about the  personal information we gather and use about you, how it is used, stored, Kand transferred, for what purposes, the steps taken to keep that information  secure and for how long it is kept. 

• your rights and obligations in relation to data protection; and 

• the consequences of failure to comply with this policy. 

1 Introduction 

1.1 The Company obtains, keeps and uses personal information (also referred to  as data) about job applicants and about current and former employees,  temporary and agency workers, contractors, interns, volunteers and  apprentices for a number of specific lawful purposes. 

1.2 This policy sets out how we comply with our data protection obligations and  seek to protect personal information relating to our workforce. Its purpose is  also to ensure that staff understand and comply with the rules governing the  collection, use and deletion of personal information to which they may have  access in the course of their work. 

1.3 We are committed to complying with our data protection obligations, and to  being concise, clear and transparent about how we obtain and use personal  information relating to our workforce, and how (and when) we delete that  information once it is no longer required. 

1.4 The Company’s data protection officer, Kevin Styles DPRO, is responsible for  informing and advising the Company and its staff on its data protection  obligations, and for monitoring compliance with those obligations and with the  Company’s policies. If you have any questions or comments about the content  of this policy or if you need further information, you should contact the data  protection officer. 

2 Scope 

2.1 This policy applies to the personal information of job applicants and current  and former staff, including employees, temporary and agency workers,  interns, volunteers and apprentices. 

2.2 Staff should refer to the Company’s data protection privacy notice and, where  appropriate, to its other relevant policies including in relation to internet, email  and communications, monitoring, social media, information security, data  retention and criminal record information, which contain further information  regarding the protection of personal information in those contexts.

Fastline Services Ltd – Data Protection Policy – 2018 

2.3 We will review and update this policy at least annually in accordance with our  data protection obligations. It does not form part of any employee’s contract of  employment, and we may amend, update or supplement it from time to time.  We will circulate any new or modified policy to staff when it is adopted. 

3 Definitions 

criminal  

records  

information 

means personal information relating to criminal  convictions and offences, allegations, proceedings, and  related security measures; 

data breach means a breach of security leading to the accidental or  unlawful destruction, loss, alteration, unauthorised  

disclosure of, or access to, personal information; 

data subject means the individual to whom the personal information  relates; 

personal  information 

processing  information 

(sometimes known as personal data) means information  relating to an individual who can be identified (directly or  indirectly) from that information; 

means obtaining, recording, organising, storing,  amending, retrieving, disclosing and/or destroying  information, or using or doing anything with it; 

pseudonymised means the process by which personal information is  processed in such a way that it cannot be used to identify  an individual without the use of additional information,  

which is kept separately and subject to technical and  

organisational measures to ensure that the personal  

information cannot be attributed to an identifiable  

individual; 

sensitive  personal  information 

(also known as ‘special categories of personal data’ or  ‘sensitive personal data’) means personal information  about an individual’s race, ethnic origin, political opinions,  religious or philosophical beliefs, trade union membership  (or non-membership), genetics information, biometric  information (where used to identify an individual) and  information concerning an individual’s health, sex life or  sexual orientation. 

4 Data protection principles 

4.1 The Company will comply with the following data protection principles when  processing personal information: 

4.1.1 we will process personal information lawfully, fairly and in a transparent  manner. 

4.1.2 we will collect personal information for specified, explicit and legitimate  purposes only, and will not process it in a way that is incompatible with  those legitimate purposes.

Fastline Services Ltd – Data Protection Policy – 2018 

4.1.3 we will only process the personal information that is adequate,  relevant, and necessary for the relevant purposes. 

4.1.4 we will keep accurate and up to date personal information and take  reasonable steps to ensure that inaccurate personal information is deleted or corrected without delay. 

4.1.5 we will keep personal information in a form which permits identification  of data subjects for no longer than is necessary for the purposes for  which the information is processed; and 

4.1.6 we will take appropriate technical and organisational measures to  ensure that personal information is kept secure and protected against  unauthorised or unlawful processing, and against accidental loss,  destruction, or damage. 

5 Basis for processing personal information 

5.1 We will only process personal data where we have a legal justification for  doing so, which will be set out in the Company’s data protection privacy  notice. 

6 Sensitive personal information 

6.1 Sensitive personal information is sometimes referred to as ‘special categories  of personal data’ or ‘sensitive personal data’. 

6.2 The Company may from time to time need to process sensitive personal  information. We will only process sensitive personal information if: 

6.2.1 we have a lawful basis for doing so as set out above, e.g. it is  necessary for the performance of the employment contract, to comply  with the Company’s legal obligations or for the purposes of the  

Company’s legitimate interests; and 

6.2.2 one of the special conditions for processing sensitive personal  information applies. 

6.3 The Company’s data protection privacy notice will set out the types of  sensitive personal information that the Company processes, what it is used for  and the lawful basis for the processing. 

7 Criminal records information 

7.1 Where we are required by law to carry out criminal record checks then we will  do so, and the information received will be used to make the appropriate  recruitment / employment decision and then destroyed. We will not retain  criminal records information for any more than 6 months. 

8 Privacy notice 

8.1 The Company will issue privacy notices from time to time, informing you about  the personal information that we collect and hold relating to you, how you can  expect your personal information to be used and for what purposes. 

8.2 We will take appropriate measures to provide information in privacy notices in  a concise, transparent, intelligible and easily accessible form, using clear and  plain language.

Fastline Services Ltd – Data Protection Policy – 2018 

9 Individual rights 

9.1 You (in common with other data subjects) have the following rights in relation  to your personal information: 

9.1.1 to be informed about how, why and on what basis that information is  processed—see the relevant data protection privacy notices. 

9.1.2 to obtain confirmation that your information is being processed and to  obtain access to it and certain other information, by making a subject  access request—see the Company’s subject access request policy. 

9.1.3 to have data corrected if it is inaccurate or incomplete. 

9.1.4 to have data erased if it is no longer necessary for the purpose for  which it was originally collected/processed, or if there are no overriding  legitimate grounds for the processing (this is sometimes known as ‘the  right to be forgotten’); 

9.1.5 to restrict the processing of personal information where the accuracy of  the information is contested, or the processing is unlawful (but you do  not want the data to be erased), or where the employer no longer  needs the personal information, but you require the data to establish,  exercise or defend a legal claim; and 

9.1.6 to restrict the processing of personal information temporarily where you  do not think it is accurate (and the employer is verifying whether it is  accurate), or where you have objected to the processing (and the  employer is considering whether the organisation’s legitimate grounds  override your interests). 

9.2 If you wish to exercise any of these rights, please contact the data protection  officer. 

10 Individual obligations 

10.1 Individuals are responsible for helping the Company keep their personal  information up to date. You should let the Company know if the information  you have provided to the Company changes, for example if you move to a  new house or change details of the bank or building society account to which  you are paid. 

10.2 You may have access to the personal information of other members of staff,  suppliers, and customers/clients of the Company in the course of your  employment or engagement. If so, the Company expects you to help meet its  data protection obligations to those individuals. For example, you should be  aware that they may also enjoy the rights set out above. 

10.3 If you have access to personal information, you must: 

10.3.1 only access the personal information that you have authority to access,  and only for authorised purposes. 

10.3.2 only allow other Company staff to access personal information if they  have appropriate authorisation. 

10.3.3 only allow individuals who are not Company staff to access personal  information if you have specific authority to do so from the data  

protection officer.

Fastline Services Ltd – Data Protection Policy – 2018 

10.3.4 keep personal information secure (e.g., by complying with rules on  access to premises, computer access, password protection and secure  file storage and destruction and other precautions set out in the  

Company’s information security policy); 

10.3.5 not remove personal information, or devices containing personal  information (or which can be used to access it), from the Company’s  premises unless appropriate security measures are in place (such as  pseudonymisation, encryption or password protection) to secure the  information and the device; and 

10.3.6 not store personal information on local drives or on personal devices  that are used for work purposes. 

10.4 You should contact the data protection officer if you are concerned or suspect  that one of the following has taken place (or is taking place or likely to take  place): 

10.4.1 processing of personal data without a lawful basis for its processing or,  in the case of sensitive personal information, without one of the lawful  conditions being met. 

10.4.2 any data breach as set out below. 

10.4.3 access to personal information without the proper authorisation. 10.4.4 personal information not kept or deleted securely. 

10.4.5 removal of personal information, or devices containing personal  information (or which can be used to access it), from the Company’s  premises without appropriate security measures being in place. 

10.4.6 any other breach of this policy or of any of the data protection  principles set out in paragraph 4.1 above. 

11 Information security 

11.1 The Company will use appropriate technical and organisational measures to  keep personal information secure, and to protect against unauthorised or  unlawful processing and against accidental loss, destruction or damage. 

12 Storage and retention of personal information 

12.1 Personal information (and sensitive personal information) will be kept securely  in accordance with the Company’s obligations. 

12.2 Personal information (and sensitive personal information) should not be  retained for any longer than necessary. The length of time over which data  should be retained will depend upon the circumstances, including the reasons  why the personal information was obtained. 

12.3 Personal information (and sensitive personal information) that is no longer  required will be deleted permanently from our information systems and any  hard copies will be destroyed securely. 

13 Data breaches 

13.1 A data breach may take many different forms, for example: 

13.1.1 loss or theft of data or equipment on which personal information is  stored.

Fastline Services Ltd – Data Protection Policy – 2018 

13.1.2 unauthorised access to or use of personal information either by a  member of staff or third party. 

13.1.3 loss of data resulting from an equipment or systems (including  hardware and software) failure. 

13.1.4 human error, such as accidental deletion or alteration of data. 13.1.5 unforeseen circumstances, such as a fire or flood. 

13.1.6 deliberate attacks on IT systems, such as hacking, viruses or phishing  scams; and 

13.1.7 ‘blagging’ offences, where information is obtained by deceiving the  organisation which holds it. 

14 Training 

The Company will ensure that staff are adequately trained regarding their data  protection responsibilities. Individuals whose roles require regular access to  personal information, or who are responsible for implementing this policy or  responding to subject access requests under this policy, will receive additional  training to help them understand their duties and how to comply with them. 

15 Consequences of failing to comply. 

15.1 The Company takes compliance with this policy very seriously. Failure to  comply with the policy: 

15.1.1 puts at risk the individuals whose personal information is being  processed; and 

15.1.2 carries the risk of significant civil and criminal sanctions for the  individual and the Company; and 

15.1.3 may, in some circumstances, amount to a criminal offence by the  individual. 

15.2 Because of the importance of this policy, an employee’s failure to comply with  any requirement of it may lead to disciplinary action under our procedures,  and this action may result in dismissal for gross misconduct. If a non employee breaches this policy, they may have their contract terminated with  immediate effect. 

15.3 If you have any questions or concerns about anything in this policy, do not  hesitate to contact the data protection officer. 

 

I have read and understood this policy and agree to abide by its terms