1. Definitions
- Consent: Freely given, specific, informed, and unambiguous agreement to process personal data.
- Data Controller: The organization determining the purposes and means of processing personal data (e.g., the company).
- Data Processor: A party processing personal data on behalf of the data controller.
- Data Subject: Any identifiable natural person whose personal data is held by the company.
- Personal Data: Information that identifies or relates to a data subject, including sensitive data like racial or health information.
- Processing: Any operation performed on personal data, such as storage, alteration, or erasure.
- Special Category Data: Sensitive data, such as racial or ethnic origin, health data, or religious beliefs.
2. Scope
- The company ensures lawful and fair handling of personal data and respects the rights of all data subjects.
- The Data Protection Officer (DPO) is Rob Chambers (rob@blueprintcompliance.co.uk).
- Managers must ensure compliance by their teams and implement necessary practices and training.
3. Data Protection Principles
Personal data must be:
- Processed lawfully, fairly, and transparently.
- Collected for specific, explicit, and legitimate purposes.
- Adequate, relevant, and limited to what is necessary.
- Accurate and kept up-to-date.
- Stored for no longer than necessary.
- Protected using appropriate security measures.
4. Data Subject Rights
Data subjects have the right to:
- Be informed about data collection and use.
- Access their personal data.
- Request corrections or erasure.
- Restrict processing of their data.
- Object to data processing.
- Data portability (receive and reuse their data).
- Protection against automated decision-making and profiling.
5. Lawful Data Processing
Personal data can only be processed if one of the following conditions is met:
- Consent is given.
- It is necessary for contract performance.
- It is required for compliance with legal obligations.
- It is necessary to protect vital interests.
- It serves the public interest or official authority.
- It supports legitimate interests that do not override data subject rights.
6. Data Security
- Emails containing personal data must be encrypted and marked as “confidential.”
- Personal data should be transmitted over secure networks only.
- Data should be stored securely using encryption and access control.
- Backups should be encrypted and stored offsite.
7. Accountability and Record-Keeping
- The DPO oversees compliance and develops related policies.
- Data protection impact assessments (DPIAs) must be conducted for high-risk processing activities.
- Regular audits ensure adherence to data protection laws.
8. Implementation
This policy takes effect on 7th December 2024. It applies only to activities occurring on or after this date.