• Policy prepared by: Mavis Ng
• Policy became operational on: September 1st 2020
• Next review date: August 31st 2021.
Why this policy exists
This data protection policy ensures HappyMe Career:
• Complies with data protection law and follow good practice.
• Protects the rights of staff, 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
To comply with Data Protection 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:
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
This policy applies to:
• The head office and branches of HappyMe Career.
• All staff and volunteers of HappyMe Career.
• All contractors, suppliers and other people working on behalf of HappyMe Career.
• Postal addresses
• Email addresses
• Telephone numbers
• …plus any other information relating to individuals
Data protection risks
• 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 gained access to sensitive data.
Everyone who works for or with HappyMe Career has some responsibility for ensuring 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 data protection principles.
However, these people have key areas of responsibility:
• Dealing with requests from individuals to see the data HappyMe Career 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.
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 their line managers.
• HappyMe Career 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:
• 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.
• 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 CD or DVD), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
• 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 mobile devices like tablets or smart phones.
• All servers and computers containing data should be protected by approved security software and a firewall.
• 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.
• Personal data should never be transferred outside of the European Economic Area.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires HappyMe Career 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 HappyMe Career 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.
• HappyMe Career will make it easy for data subjects to update the information HappyMe Career holds about them. For instance, via the company website.
• 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.
Subject access requests
All individuals who are the subject of personal data held by HappyMe Career 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 this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the Data Protection Office. The Data Protection Office can supply a standard request form, although individuals do not have to use this.
The Data Protection Officer will aim to provide the relevant data within 14 days, or provide an alternative response as necessary.
The Data Protection Office will always verify the identity of anyone making a subject access request before handing over any information.
Disclosing data for other reasons
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, HappyMe Career will disclose requested data. However, the Data Protection Officer will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.
HappyMe Career 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
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.