SR Supply Chain Consultants Ltd 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.
Why this policy exists
- This data protection policy ensures SR Supply Chain Consultants Ltd:
- Complies with the Data Protection Act 2018 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
The Data Protection Act 2018 describes how organisations — including SR Supply Chain Consultants Ltd 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 the data protection principles:
- Used fairly, lawfully and transparently
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and limited to what only is necessary
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Handled in a way that ensures appropriate security, including protection against unlawful or unauthorised processing, access, loss, destruction or damage
People, risks and responsibilities
This policy applies to:
- The head office of SR Supply Chain Consultants Ltd
- All study centres of SR Supply Chain Consultants Ltd
- All staff and associates of SR Supply Chain Consultants Ltd
- All contractors, suppliers and other people working on behalf of SR Supply Chain Consultants Ltd
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 2018. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Date of birth
- …plus any other information relating to individuals
Data protection risks
This policy helps to protect SR Supply Chain Consultants Ltd from some very real data 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 gained access to sensitive data.
Everyone who works for or with SR Supply Chain Consultants Ltd 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:
- The Managing Director is ultimately responsible for ensuring that SR Supply Chain Consultants Ltd meets its legal obligations.
- The Operations Manager is responsible for:
- Keeping the Managing Director 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 requests from individuals to see the data SR Supply Chain Consultants Ltd 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 Support Officer 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 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 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 their line managers.
- SR Supply Chain Consultants Ltd 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 in line with the password policy.
- 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 (unless a contract provides that it should be kept).
- 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 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.
Personal data is of no value to SR Supply Chain Consultants Ltd 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:
- 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 SR Supply Chain Consultants Ltd 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 SR Supply Chain Consultants Ltd 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.
- SR Supply Chain Consultants Ltd will make it easy for data subjects to update the information SR Supply Chain Consultants Ltd 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.
- It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject access requests
All individuals who are the subject of personal data held by SR Supply Chain Consultants Ltd 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 controller at email@example.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.
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, SR Supply Chain Consultants Ltd 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.
SR Supply Chain Consultants Ltd 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.
Related policies, registration and certificates:
Password Policy: POL 27
ICO Registration Number: ZA121375
Cyber Essentials Certificate Number: QGCE 3032
PRIVACY NOTICE – HOW WE USE YOUR DATA
- The categories of learner information that we collect, hold and share include:
- Personal information (such as name, DOB, ULN, CIPS number, address, National Insurance number, employer details, email address)
- Characteristics (such as ethnicity, language, nationality)
- Attendance information (such as session attended, number of absences and absences and reasons)
- Assessment of educational progress & outcomes, development and behaviour including that relating to special needs
- Why we collect and use this information
We use learner data:
- To support learning
- To monitor and report on learner progress
- To provide appropriate support and care
- To assess the quality of our services
- To comply with the law regarding data sharing
- To safeguard learners
- To comply with ESFA data collections requirements (apprentices only – see ESFA Data Sharing Policy)
- To process learners Chartered Institute of Procurement and Supply (CIPS) membership and assessment entry
- Marketing – we may use your contact details to provide you with information on upcoming courses, procurement and supply news, key dates and deadlines and special offers and promotions. We may use a 3rd party provider to send out these emails. You can opt out of these emails by clicking “unsubscribe” at the bottom.
The lawful basis on which we use this information
On the 25th May 2018 the Data Protection Act 1998 will be replaced by the General Data Protection Regulation (GDPR). The condition for processing under the GDPR will be:
We collect and use learner information under Article 6 ad Article 9 for reasons of:
- Necessity to perform our contract
- Necessity to comply with ESFA ILR data collection requirements
- Necessity to enter learners for the Chartered Institute or Procurement and Supply (CIPS) assessments
Storing learner data
We hold learner data on our cloud, Aptem, CRM and e-portfolio and potentially Xero, accounts, until up until 3 years after the learner has completed their training. All servers are based in the UK and have the relevant security measures in place in the line with GDPR.
Collecting learner information
The information we collect through our registration forms is based on the requirements of the Chartered Institute of Procurement and Supply (CIPS), and in the case of apprentices, the ESFA. In order to comply with the General Data Protection Regulation, we will inform you whether you are required to provide certain information or whether it is voluntary.
Who we share learner information with
We share learner information as required with the following parties:
- Chartered Institute of Procurement and Supply (CIPS)
- The Education and Skills Funding Agency (ESFA)
- Learner Record Service
Why we share learner information
We share learner information with on statutory basis. The data sharing is required for the awarding of the CIPS certifications and in the case of apprenticeships for the drawdown of levy funding. Please see the ESFA Data Sharing policy for more information.
Requesting access to your data
Under the GDPR legislation, learners have the right to request access to the information we hold about them. To make a request for your personal information please contact firstname.lastname@example.org.
You have the right to:
- Prevent processing for the purpose of direct marketing
- Object to decisions being taken by automated means
- In certain circumstances have inaccurate personal data rectified, blocked, erased or destroyed
- Claim compensation for damages caused by breach of GDPR regulations
- Object to processing of personal data that is likely to cause, or is causing damage or distress
If you have a concern about the way we collect or use your personal data please raise the concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns
If you would like to discuss please contact:
SR Supply Chain Consultants Ltd
Business First Centre