Barry Bennett Privacy policy (GDPR 2018)

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Barry Bennett Privacy policy (GDPR 2018)

The primary purpose of a privacy policy is to ensure Barry Bennett complies with information disclosure obligations under data protection legislation. From 25 May 2018 in the UK and elsewhere in the EU, that includes the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). Failure to comply may lead to civil liability and/or criminal law penalties.

Barry Bennett is, herein after, referred to as “We”, “Us” and “Our” unless specified otherwise.

The latest GDPR policy is available via this link

General Data Protection Regulation
In collecting and using data Barry Bennett must comply with the GDPR requirements as it governs the processing of personal data. Barry Bennett is identified as a Data Controller under the legislation and the Contracts and Compliance Officer is our Data Protection Officer. The personal data provided to us during the supply of equipment, installation and support is securely held by us on a central computer facility and will be treated confidentially and with sensitivity for the benefit of the company and staff so our commitments can be fulfilled.

Data Protection Principles
Barry Bennett is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:

  1. Processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
  6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
General Provisions
  1. This policy applies to all personal data processed by us.
  2. The Responsible Person shall take responsibility for our ongoing compliance with this policy.
  3. This policy shall be reviewed at least annually.
  4. We shall continually register with the Information Commissioner’s Office as an organisation that processes personal data.
Lawful, Fair and Transparent Processing
  1. To ensure its processing of data is lawful, fair and transparent, we shall maintain a Register of Systems.
  2. The Register of Systems shall be reviewed at least annually.
  3. Individuals have the right to access their personal data and any such requests made to us shall be dealt with in a timely manner.
Lawful Purposes
  1. All data processed by Barry Bennett must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
  2. Barry Bennett shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available and systems will be in place to ensure such revocation is reflected.
Data Minimisation
  1. We shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  2. We will only collect the required data to ensure procurement policies and requiremnents are adheared to and to ensure we can continue agreed length of contractual agreements thereafter.
  1. We shall take reasonable steps to ensure personal data is accurate.
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
Individual’s Rights
Under GDPR, we acknowledge the following rights of the individual, in respect of any personal data that we hold:

  1. The right to be informed
  2. The right of access
  3. The right to rectification
  4. The right to erasure
  5. The right to restrict processing
  6. The right to data portability
  7. The right to object
  8. The right not to be subject to automated decision-making including profiling
Archiving / Removal
  1. To ensure that personal data is kept for no longer than necessary, we shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.
  1. We shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
  3. When personal data is deleted this should be done safely such that the data is irrecoverable.
  4. Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, we shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).

This document was created in May 2018 and is due for review in May 2019.