Collaborate Digital needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, schools, school children, 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.
This data protection policy ensures Collaborate Digital:
General Data Protection Regulation describes how organisations — including Collaborate Digital — 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.
Article 5 of the GDPR requires that personal data shall be:
a) processed lawfully, fairly and in a transparent manner in relation to individuals;
b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and
organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
Collaborate Digital has determined that the most appropriate lawful basis for processing data is ‘legitimate interests’. A Legitimate Interests Assessment has been carried out for the day to day operations of the business and specific assessments are carried out for each individual project.
This policy applies to:
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:
This policy helps to protect Collaborate Digital from some very real data security risks, including:
Everyone who works for or with Collaborate Digital 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 is responsible for:
Specific guidance is yet to be published with regard to taking photographs (and by extent video and audio) in schools under the GDPR regulations.
However, guidance under the Data Protection Act 1998 (the DPA) states that:
“The DPA is unlikely to apply in many cases where photographs are taken in schools and other educational institutions. Fear of breaching the provisions of the DPA should
not be wrongly used to stop people taking photographs or videos which provide many with much pleasure. Where the DPA does apply, a common sense approach suggests that if the photographer asks for permission to take a photograph, this will usually be enough to ensure compliance.”
However, in the absence of clear guidance, Collaborate Digital assumes that the voice or image of a child recorded in audio or video does constitute personal data. As such we require a parental consent form to be completed for each participating child.
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 data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
Personal data is of no value to Collaborate Digital 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:
The law requires Collaborate Digital 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 Collaborate Digital 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.
All individuals who are the subject of personal data held by Collaborate Digital are entitled to:
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 firstname.lastname@example.org 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.
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, Collaborate Digital 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.
Collaborate Digital aims to ensure that individuals are aware that their data is being processed, and that they understand:
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.
[This is available on request. A version of this statement is also available on the company’s website.]