Privacy Policy

Introduction

This policy covers Project Georgia (Topco) limited and all its subsidiaries.

We hold personal data about our employees, clients, suppliers and other individuals for a variety of business purposes.

This policy sets out how we seek to protect personal data and ensure that employees understand the rules governing their use of personal data to which they have access in the course of their work. In particular, this policy requires employees to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.

Definitions

Scope

This policy applies to all employees. You must be familiar with this policy and comply with its terms.

This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to employees before being adopted.

Who is responsible for this policy?

As our Data Protection Officer, Arlene Steele has overall responsibility for the day-to-day implementation of this policy.

Our procedures

Fair and lawful processing

We must process personal data fairly and lawfully in accordance with individuals’ rights. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.

The Data Protection Officer’s responsibilities:

• Keeping the board updated about data protection responsibilities, risks and issues
• Reviewing all data protection procedures and policies on a regular basis
• Answering questions on data protection from employees, board members and other stakeholders
• Responding to individuals such as clients and employees who wish to know which data is being held on them by Prohire.
• Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing

Responsibilities of the IT Manager

• Ensure all systems, services, software and equipment meet acceptable security standards
• Checking and scanning security hardware and software regularly to ensure it is functioning properly
• Researching third-party services, such as cloud services the company is considering using to store or process data

Responsibilities of the Customer Relations Manager

• Approving data protection statements attached to emails and other marketing copy
• Addressing data protection queries from clients, target audiences or media outlets
• Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy

Responsibilities of the Finance Manager

• Archiving – organisations must keep a well-managed archive of invoices. Although this is a simple principle, paper records may be kept in different locations, and electronic records may be saved in various different places. Meanwhile, organisations will be required to make sure that archived records are unchanged and untampered, and that records are destroyed after a set retention period.
• Data access – Organisations must provide customers or suppliers with records of their personal data on request. This must be provided quickly and presented in a format that the customer can read and re-use.
• Record keeping – Organisations will be required to keep internal records of data processing and record management systems must be able to extract raw data and providing a full audit history of records kept.
• Removing records – On request, organisations must remove data held on a customer or supplier who withdraws consent for it to be kept. Ensuring every piece of relevant data is removed and doing so in a way that doesn’t impact other records.

The responsibilities of the HR Manager

• Organisations may keep personal data only for as long as necessary. For example, in an application process, the data of candidates who are not employed should be deleted shortly after recruitment process, unless candidates have given explicit consent. Also, the data of employees who leave a company (by resignation, because they have found another job or have been dismissed) may only be retained for a limited amount of time.
• Employers may only request data from potential employees if it is necessary. For all other forms of data collection, explicit permission must be requested. The same applies to the data of current employees. Any data companies hold on their employees must be for good reason.
• Companies are required to provide insight into how and where employee data is stored and processed. For information that requires employee permission, their consent must also be held by the company. This is not final, employees have the right to withdraw their permission. It should also be made clear who has access to what data. To make this transparency possible, companies must critically review their current architecture of stored data.

The processing of all data must be:

• Necessary to deliver our services
• In our legitimate interests and not unduly prejudice the individual’s privacy
• In most cases this provision will apply to routine business data processing activities.

Sensitive personal data

In most cases where we process sensitive personal data we will require the data subject’s explicit consent to do this unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.

Accuracy and relevance

We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO, Arlene Steele.

Your personal data

You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required. For example, if your personal circumstances change, please inform the Data Protection Officer so that they can update your records.

Data security

You must keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third party organisations.

Storing data securely

• In cases when data is stored on printed paper, it should be kept in a secure place where unauthorised personnel cannot access it.
• Printed data should be shredded when it is no longer needed.
• Data stored on a computer should be protected by strong passwords that are changed regularly. We encourage all employees to use a password manager to create and store their passwords.
• Data stored on CDs or memory sticks must be locked away securely when they are not being used.
• The DPO must approve any cloud used to store data.
• Servers containing personal data must be kept in a secure location, away from general office space.
• Data should be regularly backed up in line with the company’s backup procedures.
• Data should never be saved directly to mobile devices such as laptops, tablets or smartphones. In cases where this is unavoidable (field employees, Directors), Mobile Device Management software will be installed.
• Company data should not be stored on any device which is not owned by the Company. This includes Company email accounts on personal mobile telephones. Should there be a necessity to access company emails and data on a personal mobile telephone, the employee must agree to follow company requirements for encryption/protection.
• All servers containing sensitive data must be approved and protected by security software and strong firewall.

Data retention

We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner consistent with our data retention guidelines.

Transferring data internationally

There are restrictions on international transfers of personal data. You must not transfer personal data anywhere outside the UK without first consulting the Data Protection Officer.

Subject access requests

Please note that under the Data Protection Act 1998, individuals are entitled, subject to certain exceptions, to request access to information held about them.

If you receive a subject access request, you should refer that request immediately to the DPO. We may ask you to help us comply with those requests.

Please contact the Data Protection Officer if you would like to correct or request information that we hold about you. There are also restrictions on the information to which you are entitled under applicable law.

Processing data in accordance with the individual’s rights

You should abide by any request from an individual not to use their personal data for direct marketing purposes and notify the DPO about any such request.

Do not send direct marketing material to someone electronically (e.g. via email) unless you have an existing business relationship with them in relation to the services being marketed.

Please contact the DPO for advice on direct marketing before starting any new direct marketing activity.

GDPR provisions

Where not specified previously in this policy, the following provisions will be in effect on or before 25 May 2018.

Privacy Notice – transparency of data protection

Being transparent and providing accessible information to individuals about how we will use their personal data is important for our organisation. The following are details on how we collect data and what we will do with it:

Conditions for processing

We will ensure any use of personal data is justified using at least one of the conditions for processing and this will be specifically documented. All employees who are responsible for processing personal data will be aware of the conditions for processing. The conditions for processing will be available to data subjects in the form of a privacy notice.

Justification for personal data

We will process personal data in compliance with all six data protection principles. (The below are hyperlinks, please hold down your control button to access)

Principle 1 – fair and lawful

Principle 2 – purposes

Principle 3 – adequacy

Principle 4 – accuracy

Principle 5 – retention

Principle 6 – rights

We will document the additional justification for the processing of sensitive data, and will ensure any biometric and genetic data is considered sensitive.

Data portability

Upon request, a data subject should have the right to receive a copy of their data in a structured format. These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This must be done for free.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Right to be forgotten

A data subject may request that any information held on them is deleted or removed. An erasure request can only be refused if an exemption applies.

Reporting breaches

All members of employees have an obligation to report actual or potential data protection compliance failures. This allows us to:

• Investigate the failure and take remedial steps if necessary
• Maintain a register of compliance failures
• Notify the Data Protection Officer who will in turn notify the Supervisory Authority (ICO) of any compliance failures that are material either in their own right or as part of a pattern of failures

Monitoring

Everyone must observe this policy. The DPO has overall responsibility for this policy. They will monitor it regularly to make sure it is being adhered to.

Consequences of failing to comply

We take compliance with this policy very seriously. Failure to comply puts both you and the organisation at risk.

The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in dismissal.

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