DATA PROTECTION POLICY
The Squad Management needs to gather and use certain information about
These can include customers, suppliers, business contacts, employees and
other people the organisation has a relationship with or may need to
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
Why this policy exists
This data protection policy ensures The Squad Management:
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
The Data Protection Act 1998 describes how organisations - including The
Squad Management 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:
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 The Squad Management
All staff of The Squad Management
All contractors, suppliers and other people working on behalf of The
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 1998. This can include:
Names of individuals
Plus, any other information relating to individuals
Data protection risks
This policy helps to protect The Squad Management 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 The Squad Management 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 director
is ultimately responsible for ensuring that The Squad Management meets its
The data protection officer
is responsible for:
Keeping the board updated about data protection responsibilities, risks
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
Handling data protection questions from staff and anyone else covered by
Dealing with requests from individuals to see the data The Squad
Management 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 Manager/Company
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.
The Managing Director
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
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.
The Squad Management 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
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
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
When data is stored electronically, it must be protected from unauthorised
access, accidental deletion and malicious hacking attempts:
Data should be protected with 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 The Squad Management 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
company can explain how to send data to authorised external contacts.
Personal data should never be transferred outside of the European
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 Squad Management 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 Squad Management 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
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.
The Squad Management will make it easy for data subjects to update the
information The Squad Management holds about them. For instance, via the
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 The Squad
Management 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 firstname.lastname@example.org. The data controller
can supply a standard request form, although individuals do not have to use
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
Under these circumstances, The Squad Management 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
The Squad Management 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.