Boss Design 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.
The Data Protection Act 1998 describes how organisations — including Boss Design 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.
Everyone who works for or with Boss Design has some responsibility for ensuring data is collected, stored and handled appropriately.
Each person that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
Key areas of responsibility:
The board of directors is ultimately responsible for ensuring that Boss Design meets its legal obligations.
The data protection officer, Virginia Seaward, is responsible for:
o Keeping the board updated about data protection responsibilities, risks and issues.
o Reviewing all data protection procedures and related policies, in line with an agreed schedule.
o Arranging data protection training and advice for the people covered by this policy.
o Handling data protection questions from staff and anyone else covered by this policy.
o Dealing with requests from individuals to see the data Boss Design holds about them (also called ‘subject
access requests’).
o Checking and approving any contracts or agreements with third parties that may handle the company’s
sensitive data.
The IT manager, Virginia Seaward is responsible for:
o Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
o Performing regular checks and scans to ensure security hardware and software is functioning properly.
o Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
The creative director, Ceri Lovett is responsible for:
o Approving any data protection statements attached to communications such as emails and letters.
o Addressing any data protection queries from journalists or media outlets like newspapers.
o 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.
Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
Boss Design 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.
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:
Personal data is of no value to Boss Design 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:
The law requires Boss Design 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 Boss Design 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. Boss Design will make it easy for data subjects to update the information Boss Design holds about them. 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.
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 dpo@bossdesign.com.
The data controller 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 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.
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, Boss Design 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.
Boss Design aims to ensure that individuals are aware that their data is being processed, and that they understand:
[This is available on request. A version of this statement is also available on the company’s website.]
Boss Design North America
High Point N.C. 27262
t. +1 336 889 9400
Boss Design UK
DY2 8SZ.
t. +44 (0) 1384 455570
© Boss Design.
