MJH FASHIONS Ltd
General Data Protection Policy
Context and overview
Policy prepared by: Junaid Syed, (TAY Consultants)
Approved by management: Yes
Policy became operational on: 25/05/2018
MJH Fashions 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 MJH Fashions Ltd data protection standards — and to comply with the law.
Why this policy exists
This data protection policy ensures MJH Fashions Ltd:
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
New General Data Protection regulation (GDPR) (replacing the data protection act 1998), being enforced by ICO describes how organisations including MJH Fashions 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 GDPR regulation is underpinned by eight important principles. These say that personal data must:
1. Be processed fairly and lawfully
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
8. 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 MJH Fashions Ltd
All staff of MJH Fashions Ltd
All contractors, suppliers and other people working on behalf of MJH Fashions Ltd
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR Data Protection Regulation. This can include:
Name, Email address, home address, Date of Birth and phone number, product sizes (dress, trouser, shirts, tops etc), accessorise sizes (shoes, hats, belt, etc) and any other necessary requested body measurements for customise pieces (cloth). Electronic copy of Receipts, which has partial details of customers payment cards and cannot be used for payment, Customers credit, and debit card details are also stored in some cases, in order to provide customised services, customer consent is acquired in such cases.
Date of birth, NI, Address, Marital Status, Medical health information, any disability
information, next of Kin information, Passport details, Telephone numbers, email address, other contact details of previous, potential and current employees C.V, Employment contracts or sub-contractor’s agreements if applicable.
Data protection risks
This policy helps to protect MJH Fashions 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 MJH Fashions 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 board of directors is ultimately responsible for ensuring that MJH Fashions Ltd meets its legal obligations.
The Data Protection officer Panagiota at firstname.lastname@example.org is responsible for:
o Keeping the board updated about data protection responsibilities, risks and issues.
o Managing Subject Access requests (SAR) if any, which involves documenting and responding all requests like transferring, acquiring and inquiring of personal information held by MJH Fashions Ltd, made by an individual or an organisation, relating to customers, contractors, associates, partners and staff of MJH Fashions Ltd.
o Managing Subject Access Amendment requests (SAA) if any, which involves
documenting and responding all requests made for changes and updates of personal information held by MJH Fashions Ltd, made by an individual or an organisation, relating to customers, contractors, associates, partners and staff of MJH Fashions Ltd.
o Validating fully all above requests before responding to them.
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 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.
MJH Fashions 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.
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 company’s 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 data protection officer. 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.
Printouts data is kept in record, as long as necessary, i.e. when required by applicable law or by legitimate business reason, for example when there is a contract with MJH Fashions Ltd and for as long as it is required by law, after the contract is expired, for example when there is a contract with MJH Fashions Ltd and for as long as it is required by law, after the contract is expired, for example, keeping psychometric data is only valid for 2 years and therefore deleted after that. Consent Forms (called as “Customer Details & Consent Form”) are required to be signed by customers where appropriate for example for sending newsletters and marketing information to customers. We will review the data and ask for client’s and employee’s consent whether to keep, hold, transfer or remove the data, where necessary, for example, other than the Legal requirements mentioned above. Where we must archive the data, we will implement reasonable measures to prevent the Personal Data and will only use if required for legitimate business purpose.
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 or Memory Sticks), 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.
Electronic data is kept in record, as long as necessary, i.e. when required by applicable law or by legitimate business reason, for example when there is a contract with MJH Fashions Ltd and for as long as it is required by law, after the contract is expired, for example when there is a contract with MJH Fashions Ltd and for as long as it is required by law, after the contract is expired, for example, keeping psychometric data is only valid for 2 years and therefore deleted after that. Consent Forms (called as “Customer Details & Consent Form”) are required to be signed by customers where appropriate for example for sending newsletters and marketing information to customers. We will review the data and ask for client’s and employee’s consent whether to keep, hold, transfer or remove the data, where necessary, for example, other than the Legal requirements mentioned above. Where we must archive the data, we will implement reasonable measures to prevent the Personal Data and will only use if required for legitimate business purpose.
Personal data is of no value to MJH Fashions 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.
MJH Fashions Ltd ensures that data is gone to the right recipient, whether communicated electronically or by other means.
Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data on the company secured server/computers.
The law requires MJH Fashions 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 MJH Fashions 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.
MJH Fashions Ltd will make it easy for data subjects to update the information MJH Fashions
Ltd holds about them and ensures the authenticity of any requests made.
Data should be updated as inaccuracies are discovered.
Subject access requests
All individuals who are the subject of personal data held by MJH Fashions 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 contact 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 i.e. clients of MJH Fashions Ltd. The data controller can supply a standard request form, although individuals do not have to use this.
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, MJH Fashions 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.