Data Protection Policy
Policy prepared by: Zulf Choudhary
Approved by board / management on: 03/12/2020
Policy became operational on: 03/12/2020
Next review date 29/11/2020
ICO number ZA572012
2. Sparta Software Ltd ((Company reg: 05483096) with registered office at Registered office: Charter Buildings, 9 Ashton Lane, Sale, Trafford, England, M33 6WT), t/a Sparta Consulting needs to gather and use certain information about individuals. All references to the words ‘Sparta Consulting’ in fact refer to Sparta Software Ltd from now on.
We need to collect information on organisations, these can include customers, suppliers, business contacts, employees and other people that the organisation has a relationship with or may need to contact.
This policy describers how 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 Sparta Consulting:
· 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 Data Protection Act 1998 describes how organisations – including Sparta Consulting 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 eight important principles. These say that personal data must:
1. Be processed fairly and lawfully;
2. Be obtained only for specific, lawful, purposes;
3. Be adequate, relevant and not excessive;
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 appropriate ways;
8. 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
This policy applies to:
· The head office of Sparta Consulting.
· All branches of Sparta Consulting.
· All staff and volunteers of Sparta Consulting.
· All contractors, suppliers and other people working on behalf of Sparta
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 1998. This can include:
· Names of individuals;
· Postal addresses;
· Email addresses;
· Telephone numbers;
· Any other information relating to individuals.
Data protection risks
This policy helps to protect Sparta Consulting from some very real data security risks, including:
· Breaches of confidentiality. For instance, information being given out
· 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 Sparta Consulting 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 Sparta
Consulting meets its legal obligations.
· The data protection officer, Mohammed Choudhary, 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 Sparta Consulting 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 Manager, Zulf Choudhary, is 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 Marketing Manager, Zulf Choudhary is appointed, 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.
- Sparta Consulting will provide training to all employees to help them understand their responsibilities when handling data.
- Employees should keep all data secured, by taking sensible precautions and following the guidelines below.
- 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.
- Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
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 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.
Personal data is of no value to Sparta Consulting 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:
Subject access requests
All individuals who are the subject of personal data held by Sparta Consulting are entitled to:
· Ask what information the company holds about them and why.
· Request access to a copy of the data within 30 days.
· Request the information to be updated under instruction within 30 days.
· Be informed how the company is meeting its data protection obligations.
If an individual contact 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 firstname.lastname@example.org. 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, Sparta Consulting 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.
Sparta Consulting 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.
This is available on request. A version of this policy is also available on the company’s website.
FCA (to be arranged over Xmas)