Data Protection Policy

Introduction

Simon Edmonds Chartered Surveyors needs to gather and use certain information about individuals.

These can include clients, 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 Simon Edmonds Chartered Surveyors:

1. Complies with data protection law and follows good practice
2. Protects the rights of individuals
3. Is open about how it stores and processes individuals' data
4. Protects itself from the risks of a data breach

Data protection law

The Data Protection Act (DPA), The Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulation (GDPR) describe how organisations,

including Simon Edmonds Chartered Surveyors, must collect, handle, use 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.

DPA is underpinned by eight important principles. These say that personal data must:

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

 

Policy scope

This policy applies to Directors, staff and contractors working on behalf of Simon Edmonds Chartered Surveyors.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of The DPA, The PECR and The GDPR. This can include:

1. Names of individuals
2. Postal and email addresses
3. Telephone numbers
4. Any other information relating to individuals

 

Data protection risks

This policy helps to protect Simon Edmonds Chartered Surveyors from some very real data security risks, including:

1. Breaches of confidentiality. For instance, information being given out inappropriately.
2. Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
3. Reputation damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

 

Responsibilities

The Executive is responsible for:

1. Keeping the company updated about data protection responsibilities, risks and issues.
2. Reviewing all data protection procedures and related policies, in line with an agreed schedule.
3. Arranging data protection training and advice for the people covered by this policy.
4. Handling data protection questions from staff and anyone else covered by this policy.
5. Dealing with requests from individuals to see the data Simon Edmonds Chartered Surveyors holds about them (also called 'subject access requests').
6. Checking and approving any contracts or agreements with third parties that may handle the company's sensitive data
7. Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
8. Performing regular checks and scans to ensure security hardware and software is functioning properly.
9. Evaluating any third‐party services the company is considering using to store or process data. For instance, cloud computing services.
10. Approving any data protection statements attached to communications such as emails and letters.
11. Addressing any data protection queries from journalists or media outlets like newspapers.
12. Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

The only people able to access data covered by this policy should be those who need it for their work.  Simon Edmonds Chartered Surveyors 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 Executive if they are unsure about any aspect of data protection.

 

Data storage

These rules describe how and where data should be safely stored.

1. When not required, the paper or files should be kept in a locked drawer or filing cabinet.
2. Employees should make sure paper and printouts are not left where unauthorised people could see them, such as on a printer.
3. 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:

1. Data should be password protected
2. If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
3. Servers containing personal data should be sited in a secure location, away from general office space.
4. Data should be backed up frequently, those backups should be tested regularly, in line with the company's standard backup procedures.
5. All servers and computers containing data should be protected by approved security software and a firewall

 

Data use / security

1. When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
2. Data must be encrypted before being transferred electronically. The Executive can explain how to send data to authorised external contacts.
3. Personal data should never be transferred outside of the European Economic Area.

 

Data accuracy

The law requires us 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 we 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.

1. Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
2. Staff should take every opportunity to ensure data is updated. For instance, by confirming a client's details when they call.
3. Data should be updated as inaccuracies are discovered. For instance, if a client can no longer be reached on their stored telephone number, it should be removed from the database.

 

Information / data request

All individuals who are the subject of personal data held by Simon Edmonds Chartered Surveyors are entitled to;

1. Ask what information the company holds and why.
2. Ask how to gain access to it.
3. Be informed how to keep it up to date.
4. Be informed 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.

Please refer to the Subject Access Policy or emailing info@secommercial.co.uk

We will aim to provide the relevant data in a timely manner.  We will always verify the identity of anyone making a subject access request before handing over any information.

In certain circumstances, DPA, PECR and GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, we will disclose requested data.  However, the company will ensure the request is legitimate, seeking assistance from the Executive and from the company's legal advisers where necessary.

Simon Edmonds Chartered Surveyors aims to ensure that individuals are aware that their data is being processed, and that they understand for what reason.  Privacy Policy available by request.

 

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