Midland Fire - fire protection equipment that we sell


Midland Fire Ltd (the “Company”) needs to gather and use certain information about individuals. This can include clients, suppliers, business contacts, employees, contractors and other people the organisation has a relationship with or may need to contact. 
We are committed to maintaining the privacy of every individual we hold data on. We will never share individual data with a third party or external agencies without express permission from the individual in question. 
Although we do not collect any personal data through our website we do analyse traffic, using Google Analytics as our third-party provider, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. 
This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. 
This policy describes how this personal data must be collected, handled and stored to meet the Company’s data protection standards – and comply with the law. 
The Company and its directors will endeavour to ensure that all personal data is processed in compliance with this policy and the principles of The General Data Protection Regulations (GDPR) (Regulation (EU) 2016/679) adopted 27 April 2016, the two-year transition period and the application date of 25 May 2018 of the Data Protection Act 1998. 
Why this policy exists 
To ensure the Company: 
• Complies with data protection law and follows good practice 
• Protects the rights of staff, clients and partners 
• Is open about how it stores and processes individual’s data 
• Protects itself from the risks of a data breach 
Data protection law 
The act describes how organisations, including the Company, 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 eight important principles. These say that personal data must: 
Be processed fairly and lawfully 
Be obtained for specific and lawful purposes 
Be adequate, relevant, not excessive 
Be accurate and, where necessary up to date 
Not be kept for longer than necessary 
Be processed in accordance with the rights of data subjects 
Appropriate measures must be taken against unauthorised and unlawful processing of data or accidental loss – be protected in appropriate ways 
Not be transferred to a country outside the EEA unless that country has adequate protection for the rights of data subjects 
Policy scope - This policy applies to: 
The head office of the Company 
All staff and volunteers of the Company 
All contractors, suppliers and other people working on behalf of the Company 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. 
This can include: 
Names of individuals 
Postal address 
Email addresses 
Telephone numbers 
Plus any other information relating to individuals, such as sensitive personal data, 
meaning that personal data consisting of information as to: 
The racial or ethnic origin of the data subject 
Their political opinions 
Their religious beliefs or other beliefs of a similar nature 
Whether they are a member of a trade union 
Their physical or mental health or condition 
Their sexual life 
The commission or alleged commission by them of any offence 
Any proceedings for any offence committed or alleged to have been committed by them, the disposal of such proceedings or the sentence of any court in such proceedings 
Data protection risks 
This policy helps to protect the Company 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 
People, risks and responsibilities 
Everyone who works for, or with, the Company 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. 
However, these people have key areas of responsibility: 
The managing director is ultimately responsible for ensuring that the Company meets its legal obligations 
The Company is not required to appoint a data protection officer (DPO) under the regulations, however, the directors shall undertake that the same duties and responsibilities apply, in so far as the board of directors deem appropriate, had we been required to appoint a DPO 
The Company director Daniel Stone, or other director nominated by him, is responsible for: 
Keeping the board updated about data protection responsibilities, risks and issues 
Reviewing all data protection procedures and related policies, in line with an agreed 
Arranging data protection training and advice for people covered by this policy, in so far as is deemed necessary 
Handling data protection questions from staff and anyone else covered by this policy 
Dealing with requests from individuals to see the data the Company 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 Company office manager (and any outsourced IT services company where appointed) 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 service 
The Company directors are 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 magazines and newspapers 
Where necessary, working with other staff to ensure any 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 manager 
The Company will provide training to all employees, in so far as is deemed appropriate by the directors, 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 manager or a Company director if they are unsure about any aspect of data protection 
General staff guidelines 
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the office manager or a Company director. 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 service 
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 good 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 
Data storage 
Personal data is of no value to the Company 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 
Personal data should never be transferred outside 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 the Company 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 the Company 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 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 clients’ details when they call 
The Company will make it easy for data subjects to update the information the Company holds about them 
Data should be updated as inaccuracies are discovered. For instance, if a client can no longer be reached on their stored telephone number, it should be removed from the database, 
All individuals who are the subject of personal data held by the Company 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 a director of the Company who will aim to provide the relevant data within 14 days. Such requests should be headed ‘subject access request’. In some circumstances it may not be possible to release the information about the subject to them for example, if it contains personal data about another person. The director 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, the Company will disclose the requested data. However, the director will ensure the request is legitimate, seeking assistance from the board and from the Company’s legal advisers where necessary. 
The Company 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 
Subject access requests 
Disclosing data for other reasons 
Providing information 
Policy approved by: Danny Stone, Director. 
Title: Managing director  
Date: 25th May 2018 
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