Freshwater is registered with the Data Controller, our DP number is Z5873076
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:
In order to meet the requirements of the principles, Freshwater will:
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 Chief Executive. The Information Compliance Manager is Haydn Evans (Finance Director ), e-mail: firstname.lastname@example.org
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.
This policy has been approved by the Chief Executive 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.
All individuals who are the subject of personal data held by Freshwater are entitled to:
All employees are responsible for:
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:
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.
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.
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.