Privacy Policy

1 CONTEXT AND OVERVIEW

Introduction
TrellisWorks needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, 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.

Why this policy exists?
This data protection policy ensures TrellisWorks complies with data protection law and follows good practice, protects the rights of staff, customers and partners, and that it is open about how it stores and processes individuals’ data and protects itself from the risks of a data breach.

Data protection law
The Data Protection Act describes how organisations, including TrellisWorks, must collect, handle and store personal information and these rules apply regardless of whether data is stored electronically, on paper or 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:

  • Be processed fairly and lawfully
  • Be obtained only for specific, lawful purposes
  • Be adequate, relevant and not excessive
  • Be accurate and kept up to date
  • Not be held for any longer than necessary
  • Processed in accordance with the rights of data subjects
  • Be protected in appropriate ways
  • Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

2 PEOPLE, RISKS AND RESPONSIBILITIES

Policy scope
This policy applies to all staff and volunteers of TrellisWorks, all contractors, suppliers and other people working on behalf of Trellisworks.

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. This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • And/or any other information relating to individuals

Data protection risks
This policy helps to protect TrellisWorks from some very real data security risks, including:

  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • 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.

Responsibilities

Everyone who works for or with TrellisWorks 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 TrellisWorks meets its legal obligations.
  • The data protection officer 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 [company name) 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 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 service, the company is considering using to store or process data. For instance, cloud computing services.
  • The marketing manager 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.

3 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.

TrellisWorks will provide training to all employees to help them understand their responsibilities when handling data.

Employees should keep all data secure, 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.

4 DATA STORAGE

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 an 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 smartphones.
  • All servers and computers containing data should be protected by approved security software and a firewall.

5 DATA USE, GDPR & LEGITIMATE INTEREST ASSESSMENT

Personal data is of no value to TrellisWorks 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:

  • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally
  • Personal data should never be transferred outside of the European Economic Area.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

TrellisWorks has conducted an LIA of the data it keeps regarding potential new clients. Readily available contact data, for example, a person’s name, email address, position and company is processed by TrellisWorks in order to notify them of our services. This is beneficial to the individual and the companies Trellisworks contact because we keep up to date with the latest technology and connectivity advancements so organisations can remain competitive, effective and efficient themselves. The impact of not keeping up with certain trends in the marketplace could threaten the future of the organisation. The data is kept secure and is used only by the TrellisWorks Group and is not passed on or sold to any other third party. Also, the data is reviewed on a 12-month basis and strict filtering takes place if the contact wishes to be deleted or does not respond after 6 attempts are made to engage. Only a maximum of 2 emails are sent per month so as not to over-burden the contact. TrellisWorks deem this process reasonable because the very nature of our industry and the people we do business with is technology-based, any other form of contacting potential new clients would be more intrusive, time-consuming for the recipient themselves and have a negative impact on the environment.

6 DATA ACCURACY

The law requires TrellisWorks 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 TrellisWorks 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.

  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
  • Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
  • It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

7 SUBJECT ACCESS REQUESTS

All individuals who are the subject of personal data held by TrellisWorks are entitled to:

  • Ask what information the company holds about them and why.
  • Ask how to gain access to it.
  • Be informed about how to keep it up to date.
  • Be informed on how the company is meeting its data protection obligations.

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 [[email protected]]. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals may 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.

8 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, Trellisworks 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.

9 PROVIDING INFORMATION

TrellisWorks 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