Introduction

STSPC Ltd (“we”, “us”, “STS PC”) 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 company’s data protection standards and to comply with the law.

Why this policy exists

This data protection policy ensures STSPC Ltd:

Complies with data protection law and follows 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 UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 describe how organisations – including STSPC 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 data protection principles say that personal data must:

Be processed lawfully, fairly and in a transparent manner
Be obtained only for specified, explicit and legitimate purposes
Be adequate, relevant and limited to what is necessary
Be accurate and kept up to date
Not be held for any longer than necessary
Be processed in accordance with the rights of data subjects
Be protected by appropriate technical and organisational measures
Not be transferred outside the UK or European Economic Area unless an adequate level of protection is ensured

People, risks and responsibilities

This policy applies to:

All branches of STSPC Ltd
All staff of STSPC Ltd
All contractors, suppliers and other people working on behalf of STSPC Ltd
All data that the company holds relating to identifiable individuals

Personal data we may hold can include:

Names of individuals
Postal addresses
Email addresses
Telephone numbers
IP addresses
Referrer URLs
Browser user-agent strings

Data protection risks

This policy helps to protect STSPC 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

Responsibilities

Everyone who works for or with STSPC 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.

The following people have key areas of responsibility:

The board of directors is ultimately responsible for ensuring that STSPC Ltd meets its legal obligations.
The data protection officer is responsible for keeping the board updated about data protection responsibilities, risks and issues; reviewing all data protection procedures and related policies; arranging data protection training and advice; handling data protection questions from staff; dealing with subject access requests; and checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
The IT manager 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; and evaluating any third-party services the company is considering using to store or process data.
The marketing manager 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; and where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

Other safeguards we apply:

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.
STSPC 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.
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.

Data storage

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 controller.

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.
If data is stored on removable media (like a USB drive), it 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 approved cloud services.
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 smartphones without approved encryption.
All servers and computers containing data should be protected by approved security software and a firewall.

Personal data is of no value to STSPC 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:

Personal data should not be shared informally.
Data must be encrypted before being transferred electronically.
Personal data should never be transferred outside of the UK or European Economic Area, unless that country or territory also ensures an adequate level of protection.
Always access and update the central copy of any data.
Data will only be used by STSPC Ltd and not shared without consent.

Data accuracy

The law requires STSPC 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 STSPC 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.
STSPC Ltd will make it easy for data subjects to update the information held about them – for instance, via the company website.
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 STSPC 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 contacts the company requesting this information, this is called a subject access request.

Subject access requests should be made by email to the data controller at support@stspc.co.uk. The data controller can supply a standard request form, although individuals do not have to use this.

Under UK GDPR, subject access requests are normally provided free of charge and the data controller will aim to provide the relevant data within one calendar month.

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 law allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, STSPC 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.

Providing information

STSPC Ltd 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

Your rights

Under UK GDPR, you have the right to:

Be informed about how your data is used
Access the data we hold about you
Rectify inaccurate data
Erase your data (“right to be forgotten”) in certain circumstances
Restrict processing of your data in certain circumstances
Data portability – receive your data in a portable format
Object to processing in certain circumstances, including direct marketing
Lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk

Data controller
STSPC Ltd
101 West End Street, Oldham, Greater Manchester OL9 6AL
Email: support@stspc.co.uk
Phone: 0161 711 1773

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