FCC Data Protection Policy
FCC (First Class Cleaning (UK) Ltd) need to gather and use sensitive and/or confidential information about individuals.
These can include employees, customers, suppliers, business contacts and other people the company 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 our legal and regulatory obligations.
Why this Policy Exists
This data protection policy ensures the FCC:
- Complies with data protection law and follows good practice
- Protects the rights of employees, customers and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of a data breach
Data Protection Law
The Data Protection Act 1988 describes how organisations including FCC 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.
The Data Protection Act is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained 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 the 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
People, Risks and Responsibilities
This policy applies to:
- The head office of FCC (First Class Cleaning (UK) Ltd)
- All branches of FCC
- All staff and volunteers of FCC
- All contractors, suppliers and other people working on behalf of FCC
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Policy Act 1998. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- …plus any other information relating to individuals
Data Protection Risks
This policy helps to protect FCC from some very real 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 gain access to sensitive data.
Everyone who works for or with FCC has some responsibility for ensuring that 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 our data protection principles.
However, these people have key areas of responsibility:
- The Board of Directors is ultimately responsible for ensuring that FCC meets its legal obligation.
- The Data Protection Officer (if appointed), 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 request from individuals to see the data FCC 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 – Debbie Grindley, 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 services the company is considering using to store or process data. For instance, cloud computing services
The Marketing Manager – Debbie Grindley, 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 our data protection principles
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 the line managers
- FCC 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 follow the guidelines below
- In particular, strong passwords must be used and they should never be shared or disclosed
- Personal data should not be shared or 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 it is no longer required it should be deleted
- Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection
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 USB, CD or DVD), these should be kept locked away securely when not in use
- Data should only be stored on designated drives
- and servers, and should only be uploaded to an approved cloud computing service
- 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 portable mobile devices like tablets or smart phones
- All servers and computers containing data should be protected by an approved security software and a firewall
Personal data is of no value to FCC unless the company can make use of it. However, it is when personal data is accessed and used that is 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. In particular, it should never be sent by email, as this form of communication is not secure
- Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts if required
- Personal data should never be transferred outside of the European Economic Area (EEA).
- Employees should not save copies of personal data to their own computers. Always access and update the original copy of any data
The law requires FCC to take reasonable steps to ensure that data is kept accurate and up-to-date. The more important it is that the personal data is accurate, the greater the effort FCC should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure is it kept as accurate and up-to-date as possible.
- Data will be held is as few places as necessary. Staff should not create any unnecessary additional copies of the data
- Staff should take every opportunity to ensure the data is updated. For instance, by confirming a customer’s details when they call
- FCC will make it easy for data subjects to update the information FCC holds about them.
- Data should be updated as and when inaccuracies are discovered. For instance, if a employee/customer can no longer be reached on their stored telephone number, it will be removed from the database
Data Access Requests
All individuals who are the subject of personal data help by FCC are entitled to:
- Ask what information the company holds about them and why
- Ask how to gain access to it
- Be informed how to keep it up to date
- Be informed how the company is meeting its data protection obligations
If an individual contacts the company requesting any information, this is called a subject access request.
Subject access requests from individuals should be made by email, text or in writing addressed to the Data Protection Officer (if appointed) or their manager at:
First Class Cleaning (UK) Ltd
Unit Factory Estate
Tel: 01482 426436
Contact Name: Debbie Grindley – Director
Telephone Number: 07826 925176
Contact Name: Tim Brough – Director
Telephone Number: 07983 659953
Email address: firstname.lastname@example.org
The data controller/manager 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/manager will aim to provide the relevant information within 14 days.
The data controller/manager will always verify the identity of anyone making a subject access request before handing over any information
Disclosing data for any other reason
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 the circumstances, FCC will disclose the requested data. However, the data controller/manager will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
FCC 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
This is available upon request.