Privacy Policy

Cristol Clear Living Ltd (CCL) 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 CCL’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures CCL:

· 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

New General Data Protection regulation (GDPR) (replacing the data protection act 1998), being enforced by ICO describes how organisations — including CCL 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 GDPR regulation 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 

Policy scope

This policy applies to:

· Office of CCL

· All staff of CCL

· All contractors, suppliers and other people working on behalf of CCL

Associates

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR Data Protection Regulation. This can include:

· Names of individuals

· Postal addresses

· Email addresses

· Telephone numbers

· Any other information relating to individuals

Data protection risks

This policy helps to protect CCL 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. As a matter of principal, CCL only uses the data for contractual obligations eg: processing bookings or payments. 

· Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with CCL has responsibility for ensuring data is collected, stored and handled appropriately and processed in line with this policy and data protection principles. However, these people have key areas of responsibility. The Director (Simon Cristol) is ultimately responsible for ensuring that CCL meets its legal obligations including:

· Keeping CCL updated about data protection responsibilities, risks and issues.

· 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 this policy.

· Handling data protection questions from staff and anyone else covered by this policy.

· Dealing with requests from individuals to see the data CCL 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.

· 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 services for data storage.

As a matter of principal, CCL does not carry out any marketing activities nor has any plans in the future nor it pass or sell data to any third parties. At present no employees and/ or sub-contractors of CCL have remote access to the data or e-mails. If this policy changes i.e. allow remote access to the data and e-mails, CCL will ensure that the hardware they use is reliable and have a similar level of protection in terms of approved security software and a firewall. 

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the 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.

· Individuals should make sure paper and printouts are not left where unauthorised people could see them, like on a printer. 

· Printouts should be shredded and disposed of securely when no longer required except when there is a contract with CCL and for as long as it is required by Applicable law or by legitimate business reason, after the contract, in which case we will archive the data and implement reasonable measures to prevent the Personal Data, and will only use if required for legitimate business purpose.

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. 

· 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. 

· 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.

· Electronic data will be disposed of securely when no longer required except when there is a contract with CCL and for as long as it is required by Applicable law or by legitimate business reason, after the contract, in which case we will archive the data and implement reasonable measures to prevent the Personal Data, and will only use if required for legitimate business purpose.

Data use

Personal data is of no value to CCL 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, individuals should ensure the screens of

· their computers are always locked when left unattended.

· Personal data should not be shared informally.

· ensures that Data e.g. payslips is gone to the right recipient, weather sent electronically or by other means.

· Individuals should not save copies of personal data to their own computers. Always access and update the central copy of any data on the company secured server/computers.

Data accuracy

The law requires CCL 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 CCL should put into ensuring its accuracy. It is the responsibility of all employees/individuals 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.

· Employees/individuals should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.

· CCL will make it easy for data subjects to update the information CCL holds about them and also ensures the authenticity of any requests made.

· Data should be updated as inaccuracies are discovered.

Subject access requests

All individuals who are the subject of personal data held by CCL 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 i.e. clients of CCL. The data controller can supply a standard request form, although individuals do not have to use this. 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 New General Data Protection Act (GDPR) allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, CCL 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.