Freshwater UK Data Protection Policy
Merlin Registered DP Number : PZ6392806 (Merlin is part of the Freshwater group)
Freshwater is required to maintain certain personal data about living individuals for the purposes of satisfying operational and legal obligations. Freshwater recognises the importance of the correct and lawful treatment of personal data; it maintains confidence in the organisation and provides for successful operations. The types of personal data that Freshwater may require includes information about: current, past and prospective employees; Freshwater staff members; suppliers and others with whom it communicates directly or on behalf of its clients. This personal data, whether it is held on paper, on computer or other media, will be subject to the appropriate legal safeguards as specified in the Data Protection Act 1998.
Freshwater fully supports and adheres to the eight principles of the Data Protection Act. These principles specify the legal conditions that must be satisfied in relation to obtaining, handling, processing, transportation and storage of personal data. Employees and any others who obtain, handle, process, transport and store personal data for Freshwater must adhere to these principles.
The principles require that personal data shall:
Be processed fairly and lawfully and shall not be processed unless certain
conditions are met;
Be obtained for a specified and lawful purpose and shall not be processed
in any manner incompatible with that purpose;
Be adequate, relevant and not excessive for those purposes;
Be accurate and, where necessary, kept up to date;
Not be kept for longer than is necessary for that purpose;
Be processed in accordance with the data subject's rights;
Be kept secure from unauthorised or unlawful processing and protected
against accidental loss, destruction or damage by using the appropriate
technical and organisational measures;
And not be transferred to a country or territory outside the European
Economic Area, unless that country or territory ensures an adequate level
of protection for the rights and freedoms of data subjects in relation to the
processing of personal data.
2. Satisfaction of principles
In order to meet the requirements of the principles, Freshwater will:
o observe fully the conditions regarding the fair collection and use of personal
- meet its obligations to specify the purposes for which personal data is used;
- collect and process appropriate personal data only to the extent that it is
needed to fulfil operational or any legal requirements;
- ensure the quality of personal data used;
- apply strict checks to determine the length of time personal data is held;
- ensure that the rights of individuals about whom the personal data is held,
can be fully exercised under the Act;
- take the appropriate technical and organisational security measures to
safeguard personal data;
- and ensure that personal data is not transferred abroad without suitable
Freshwater's Designated Data Controller (2008)
Freshwater's Information Compliance Manager is responsible for ensuring
compliance with the Data Protection Act and implementation of this policy on behalf
of the Managing Director. The Information Compliance Manager is Paul Cleverley
(Creative Director ), e-mail: email@example.com.
Any questions or concerns about the interpretation or operation of this policy should be taken up in the first instance with the Information Compliance Manager.
Status of the Policy
This policy has been approved by the Managing Director and any breach will be taken
seriously and may result in formal action.
Any employee who considers that the policy has not been followed in respect of
personal data about themselves should raise the matter with their Line Manager or
Freshwater's Information Compliance Manager in the first instance.3. Subject Access
All individuals who are the subject of personal data held by Freshwater are entitled
- Ask what information Freshwater holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed what Freshwater is doing to comply with its obligations under
the 1998 Data Protection Act.
All employees are responsible for:
- Checking that any personal data that they provide to Freshwater is accurate and up to date.
- Informing Freshwater of any changes to information which they have provided, e.g. changes of address.
- Checking any information that Freshwater may send out from time to time,
- giving details of information that is being kept and processed.
- If, as part of their responsibilities, employees collect information about other people
(e.g. about business practice details or personal circumstances, or about employees
in their directorate), they must comply with the Policy and with the Data Protection
The need to ensure that data is kept securely means that precautions must be taken
against physical loss or damage, and that both access and disclosure must be
restricted. All staff are responsible for ensuring that:
- Any personal data which they hold is kept securely
- Personal information is not disclosed either orally or in writing or
otherwise to any unauthorised third party.
4. Rights to Access Information
Employees and other subjects of personal data held by Freshwater have the right to access any personal data that is being kept about them on computer and also have access to paper-based data held in certain manual filing systems. This right is subject to certain exemptions which are set out in the Data Protection Act. Any person who wishes to exercise this right should make the request in writing to Freshwater's Information Compliance Manager, using the standard form which is available from the Information Compliance Manager or via the Intranet.
Freshwater reserves the right to charge the maximum fee payable for each
subject access request. If personal details are inaccurate, they can be amended upon request.
Freshwater aims to comply with requests for access to personal information as
quickly as possible, but will ensure that it is provided within 40 days of receipt of a
completed form unless there is good reason for delay. In such cases, the reason for
delay will be explained in writing to the individual making the request.
Publication of Freshwater Information
Information that is already in the public domain is exempt from the 1998 Act. This
would include, for example, information on staff contained within externally circulated
publications such as Freshwater diary. Any individual who has good reason for
wishing details in such publications to remain confidential should contact Freshwater's Information Compliance Manager.
The need to process data for normal purposes has been communicated to all data
subjects. In some cases, if the data is sensitive, for example information about
health, race or gender, express consent to process the data must be obtained.
Processing may be necessary to operate Society policies, such as health and safety
and equal opportunities.
Retention of Data
Freshwater will keep some forms of information for longer than others. All staff are
responsible for ensuring that information is not kept for longer than necessary.
The purpose for holding personal data and a general description of the categories of people and organisations to whom we may disclose it are also listed in the Data Protection register.
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