Cranleigh collects and uses information about people with whom it communicates. This personal information must be dealt with properly and securely, however it is collected, recorded and used – whether on paper, in a computer or recorded on other materials – and there are safeguards to ensure this is compliant with the Data Protection Act. Cranleigh regards the lawful and correct treatment to personal information as very important to the successful and efficient performance of its functions, and to maintain confidence between those with whom it deals. To this end Cranleigh fully endorses and adheres to the principles of Data Protection set out in the General Data Protection Regulations 2018.

 

Purpose

The purpose of this policy is to ensure that the staff of Cranleigh, Bath, is clear about the purpose and principles of Data Protection and to ensure that it has guidelines and procedures in place which are consistently followed.

Failure to adhere to these guidelines and procedures is unlawful and could result in legal action being taken against Cranleigh or its staff.

 

Principles

The General Data Protection Regulations regulate the processing of information relating to living and identifiable individuals (data subjects). This includes the obtaining, holding, using or disclosing of such information, and covers computerised records as well as manual filing systems and card indexes.

Data users must comply with the data protection principles of good practice which underpin the GDPR. To comply with the law, information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully.

To do this Cranleigh, Bath follows the eight Data Protection Principles as outlined in the GDPR , which are summarised below:

I. Personal data will be processed fairly and lawfully

II. Data will only be collected and used for specified purposes

III. Data will be adequate, relevant and not excessive

IV. Data will be accurate and up to date

V. Data will not be held any longer than necessary

VI. Data subjects’ rights will be respected

VII. Data will be kept safe from unauthorised access, accidental loss or damage

VIII. Data will not be transferred to a country outside the European Economic Area, unless that country has equivalent levels of protection for personal data.

The principles apply to “personal data” which is information held on the computer or in manual filing systems from which they are identifiable. Cranleigh employees, who process or use any personal information in the course of their duties will ensure that these principles are followed at all times.

 

Procedures

The following procedures have been developed in order to ensure that Cranleigh meets its responsibilities in terms of Data Protection. For the purposes of these procedures data collected, stored and used by Cranleigh falls into 2 broad categories:

1. Cranleigh internal data records; Staff & Contractors

2. Cranleigh external data records; clients.

Cranleigh, as a body is a DATA CONTROLLER under the Act.

 

External data records

Purposes

CRANLEIGH OBTAINS PERSONAL DATA (SUCH AS NAMES, ADDRESSES, PHONE NUMBERS AND EMAIL ADDRESS ALONG WITH PAYMENT CARD DETAILS AND OTHER DATA WHICH MAY BE CONSIDERED AS SENSITIVE DATA) FROM CLIENTS. THIS DATA IS OBTAINED, STORED AND PROCESSED SOLELY TO ASSIST STAFF IN THE EFFICIENT RUNNING OF SERVICES. PERSONAL DETAILS SUPPLIED ARE ONLY USED TO SEND MATERIAL THAT IS POTENTIALLY USEFUL. MOST OF THIS INFORMATION IS STORED ON THE ORGANISATION’S DATABASE.

CRANLEIGH  OBTAINS PERSONAL DATA AND INFORMATION FROM CLIENTS IN ORDER TO PROVIDE SERVICES. THIS DATA IS STORED AND PROCESSED ONLY FOR THE PURPOSES OUTLINED IN THE AGREEMENT AND SERVICE SPECIFICATION AGREED BY THE CLIENT EITHER ONLINE OR BY DIRECT PHONE CALL.

 

Consent

PERSONAL DATA IS COLLECTED OVER THE PHONE INTERNET BOOKING ENGINE AND BY OTHER METHODS SUCH AS E-MAIL. DURING THIS INITIAL CONTACT, THE DATA OWNER IS GIVEN AN EXPLANATION OF HOW THIS INFORMATION WILL BE USED.

WRITTEN CONSENT IS NOT REQUESTED AS IT IS ASSUMED THAT INFORMED CONSENT HAS BEEN GRANTED WHEN AN INDIVIDUAL FREELY GIVES THEIR OWN DETAILS TO SECURE THE RESERVATION/RECEIVE SERVICES.

PERSONAL DATA WILL NOT BE PASSED ON TO ANYONE OUTSIDE THE ORGANISATION WITH EXCEPTION FOR CONTRACTED DATA PROCESSING COMPANIES, WITHOUT EXPLICIT CONSENT FROM THE DATA OWNER. THIS WILL NOT BE MADE UNLESS THERE IS A LEGAL DUTY OF DISCLOSURE UNDER OTHER LEGISLATION, IN WHICH CASE THE Cranleigh MANAGEMENT WILL MAKE DISCLOSURE.

 

Access

Only the organisation’s authorised staff will have access to personal data.

All authorised staff are made aware of the Data Protection Policy and their obligation not to disclose personal data to anyone who is not supposed to have it. Information supplied is kept in a secure filing, paper and electronic system and is only accessed by those individuals involved in the delivery of the service.

Information will not be passed on to anyone outside the organisation without their explicit consent, excluding statutory bodies e.g. the HMRC.

Individuals will be supplied with a copy of any of their personal data held by the organisation if a request is made.

All confidential post must be opened by the addressee only.

 

Accuracy

Cranleigh will take reasonable steps to keep personal data up to date and accurate.

If a request is received from an organisation/individual to destroy their records, we will remove their details from the database and request that all staff holding paper or electronic details for the organisation destroy them.

 

Storage

Personal data may be kept in paper-based systems and on a password-protected computer system. Staff are required to not pass any passwords to any unauthorised individuals and lock the computer when not in use. Cranleigh personnel must report any suspicious computer behaviour and not install any software. Access to Cranleigh computer system is strictly prohibited and is allowed only for trained staff. Paper-based data is stored in organised and secure systems.

Cranleigh operates a clear desk policy at all times.

 

Use of Photographs

Cranleigh will not publish nor produce any photographs of clients unless written consent is obtained.

 

Responsibilities of employees

During the course of their duties with Cranleigh, staff will be dealing with information such as names /addresses/ phone numbers/ email addresses of employees/ clients/ contractors. They may be told or overhear sensitive information while working for Cranleigh. The GDPR gives specific guidance on how this information should be dealt with. In short to comply with the law, personal information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully. Staff, paid or unpaid must abide by this policy.

To help staff comply with the terms of the GDPR, the attached Data Protection/Confidentiality statement has been produced. Employees are asked to read and sign this statement to say that they have understood their responsibilities as part of the induction programme.

 

Compliance

Compliance with the Act is the responsibility of all staff, paid or unpaid. Cranleigh will regard any unlawful breach of any provision of GDPR by any staff member paid or unpaid, as a serious matter which.

will be dealt with under the disciplinary procedure. Any such breach could also lead to criminal prosecution.

Any questions or concerns about the interpretation or operation of this policy statement should in the first instance be referred to the line manager.

 

Retention of Data

No documents will be stored for longer than is necessary. In regards to employees and contractors the data will be kept on file for up to 6 years.

The client data in paper format will be kept for at least 6 years for records purposes.

All documents containing personal data will be disposed of securely in accordance with the Data Protection Act principles.

The client data in electronic format will be stored in password-protected computer system. Cranleigh does not store paper based document containing client personal information. Any document containing client personal data will be destroyed when no longer required.