ShineTime Cleaning Services is committed to a policy of protecting the rights and privacy of individuals, including customers, staff and others, in accordance with the General Data Protection Regulation (GDPR) May 2018.
The new regulatory environment demands higher transparency and accountability in how colleges manage and use personal data. It also accords new and stronger rights for individuals to understand and control that use.
The GDPR contains provisions that ShineTime Cleaning Services will need to be aware of as data controllers, including provisions intended to enhance the protection of customers and staffs personal data.
ShineTime Cleaning Services needs to process certain information about its staff and customers with whom it has a relationship for various purposes.
To comply with various legal obligations, including the obligations imposed on it by the General Data Protection Regulation (GDPR) STC must ensure that all this information about individuals is collected and used fairly, stored safely and securely, and not disclosed to any third party unlawfully.
This policy applies to all staff of ShineTime Cleaning Services. Any breach of this policy or of the Regulation itself will be considered an offence and disciplinary procedures will be invoked.
As a matter of best practice, individuals working with STC and who have access to personal information, will be expected to read and comply with this policy. It is expected that the staff who are responsible for dealing with external bodies will take the responsibility for ensuring that such bodies sign a contract which among other things will include an agreement to abide by this policy.
This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments to the GDPR and other relevant legislation.
General Data Protection Regulation (GDPR)
This piece of legislation comes in to force on the 25th May 2018. The GDPR regulates the processing of personal data, and protects the rights and privacy of all living individuals (including children), for example by giving all individuals who are the subject of personal data a general right of access to the personal data which relates to them. Individuals can exercise the right to gain access to their information by means of a ‘subject access request’. Personal data is information relating to an individual and may be in hard or soft copy (paper/manual files; electronic records; photographs; CCTV images), and may include facts or opinions about a person.
Responsibilities under the GDPR
ShineTime Cleaning Services will be the ‘data controller’ under the terms of the legislation – this means it is ultimately responsible for controlling the use and processing of the personal data.
Compliance with the legislation is the personal responsibility of all members of STC who process personal information.
Individuals who provide personal data to us are responsible for ensuring that the information is accurate and up-to-date.
Data Protection Principles
The legislation places a responsibility on every data controller to process any personal data in accordance with the eight principles. More detailed guidance on how to comply with these principles can be found in the DPCoP. Please follow this link to the ICO’s website (www.ico.org.uk)
In order to comply with its obligations, CTC undertakes to adhere to the eight principles:
1) Process personal data fairly and lawfully.
ShineTime Cleaning Services will make all reasonable efforts to ensure that individuals who are the focus of the personal data (data subjects) are informed of the identity of the data controller, the purposes of the processing, any disclosures to third parties that are envisaged; given an indication of the period for which the data will be kept, and any other information which may be relevant.
2) Process the data for the specific and lawful purpose for which it collected that data and not further process the data in a manner incompatible with this purpose.
ShineTime Cleaning Services will ensure that the reason for which it collected the data originally is the only reason for which it processes those data, unless the individual is informed of any additional processing before it takes place.
3) Ensure that the data is adequate, relevant and not excessive in relation to the purpose for which it is processed.
ShineTime Cleaning Services will not seek to collect any personal data which is not strictly necessary for the purpose for which it was obtained. Forms for collecting data will always be drafted with this mind. If any irrelevant data are given by individuals, they will be destroyed immediately.
4) Keep personal data accurate and, where necessary, up to date.
ShineTime Cleaning Services will review and update all data on a regular basis. It is the responsibility of the individuals giving their personal data to ensure that this is accurate, and each individual should notify if, for example, a change in circumstances means that the data needs to be updated. It is the responsibility of the STC to ensure that any notification regarding the change is noted and acted on.
5) Only keep personal data for as long as is necessary.
ShineTime Cleaning Services undertakes not to retain personal data for longer than is necessary to ensure compliance with the legislation, and any other statutory requirements. This means we will undertake a regular review of the information held and implement a weeding process. STC will dispose of any personal data in a way that protects the rights and privacy of the individual concerned (e.g. secure electronic deletion, shredding and disposal of hard copy files as confidential waste). A log will be kept of the records destroyed.
6) Process personal data in accordance with the rights of the data subject under the legislation.
Individuals have various rights under the legislation including a right to:
● be told the nature of the information STC holds and any parties to whom this may be disclosed.
● prevent processing likely to cause damage or distress.
● prevent processing for purposes of direct marketing.
● be informed about the mechanics of any automated decision making process that will significantly affect them.
● not have significant decisions that will affect them taken solely by automated process.
● sue for compensation if they suffer damage by any contravention of the legislation.
● take action to rectify, block, erase or destroy inaccurate data.
● request that the Office of the Information Commissioner assess whether any provision of the Act has been contravened.
STC will only process personal data in accordance with individuals’ rights.
7) Put appropriate technical and organisational measures in place against unauthorised or unlawful processing of personal data, and against accidental loss or destruction of data.
All members of staff are responsible for ensuring that any personal data which they hold is kept securely and not disclosed to any unauthorised third parties.
STC will ensure that all personal data is accessible only to those who have a valid reason for using it.
STC will have in place appropriate security measures e.g. ensuring that hard copy personal data is kept in lockable filing cabinets/cupboards with controlled access (with the keys then held securely in a key cabinet with controlled access):
● keeping all personal data in a lockable cabinet with key-controlled access.
● password protecting personal data held electronically.
● archiving personal data which are then kept securely (lockable cabinet).
● placing any PCs or terminals, CCTV camera screens etc. that show personal data so that they are not visible except to authorised staff.
● ensuring that PC screens are not left unattended without a password protected screen-saver being used.
In addition, STC will put in place appropriate measures for the deletion of personal data - manual records will be shredded or disposed of as ‘confidential waste’ and appropriate contract terms will be put in place with any third parties undertaking this work. Hard drives of redundant PCs will be wiped clean before disposal or if that is not possible, destroyed physically. A log will be kept of the records destroyed.
8) Ensure that no personal data is transferred to a country or a territory outside the European Economic Area (EEA) unless that country or territory ensures adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
STC will not transfer data to such territories without the explicit consent of the individual.
This also applies to publishing information on the Internet - because transfer of data can include placing data on a website that can be accessed from outside the EEA - so STC will always seek the consent of individuals before placing any personal data (including photographs) on its website.
If STC collects personal data in any form via its website, it will provide a clear and detailed privacy statement prominently on the website, and wherever else personal data is collected.
Consent as a basis for processing
Although it is not always necessary to gain consent from individuals before processing their data, it is often the best way to ensure that data is collected and processed in an open and transparent manner.
Consent is especially important when STC is processing any sensitive data, as defined by the legislation.
STC understands consent to mean that the individual has been fully informed of the intended processing and has signified their agreement whilst being of a sound mind and without having any undue influence exerted upon them. Consent obtained on the basis of misleading information will not be a valid basis for processing. Consent cannot be inferred from the non-response to a communication.
● For the purposes of the General Data Protection Regulation (GDPR)
(Regulation (EU) 2016/679 you consent STC holding and processing personal data including sensitive personal data of which you are the subject, details of which are specified in STC data protection policy.
Disclosure of Data
Legitimate disclosures may occur in the following instances:
● the individual has given their consent to the disclosure.
● the disclosure has been notified to the OIC and is in the legitimate interests of
● the disclosure is required for the performance of a contract.
There are other instances when the legislation permits disclosure without the consent of the individual.
In no circumstances will STC ell any of its databases to a third party.
Cookies are downloaded to your computer and stored on the computer’s hard drive. Such information is statistical data. This statistical data does not identify any personal details whatsoever. You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting in your chosen internet browser.
When visiting www.shinetimecleaningservices.co.uk we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
Google Analytics is a web analysis service provided by Google. Google utilises the data collected to track and examine the use of this site, to prepare reports on its activities and share them with other Google services.
Google may use the data collected to contextualise and personalise the ads of its own advertising network.
Procedure for review
This policy will be updated as necessary to reflect best practice or future amendments made to the General Data Protection Regulation (GDPR) May 2018 and Data Protection Act 1998.
Please follow this link to the ICO’s website (www.ico.org.uk) which provides further detailed guidance on a range of topics including individuals’ rights, exemptions from the Act, dealing with subject access requests, how to handle requests from third parties for personal data to be disclosed etc. In particular, you may find it helpful to read the Guide to Data Protection which is available from the website.
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