Go Well Data Protection Policy

Introduction

Go Well needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, key partners, employees, trainees, apprentices 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 General Data Protection Regulation (GDPR).

This data protection policy ensures Go Well:

• 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 Data Protection Act 1998 (DPA) describes how organisations, including Go Well, 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 DPA is underpinned by eight important principles. These say that personal data must:

1. Be processed fairly, lawfully and in a transparent manner in relation to the data subject.
2. Be obtained only for specific, explicit and lawful purposes and not be further processed in a manner that is incompatible with those purposes, except for lawful archiving, research or statistical purposes.
3. Be adequate, relevant and limited to what is necessary in relation to the purpose for which it is processed.
4. Be accurate and kept up to date. Every reasonable step must be taken to ensure inaccurate personal data is erased or rectified without delay.
5. Not be held for longer than necessary for the purposes for which it is processed, except where lawful archiving, research or statistical retention applies.
6. Be processed in accordance with the rights of data subjects and with appropriate security and protection against unauthorised or unlawful processing.
7. Be protected in appropriate ways.
8. Not be transferred outside the European Economic Area (EEA) unless that country or territory ensures an adequate level of protection.

Policy Scope

This policy applies to all staff and volunteers, including contracted staff, key partners and other people working on behalf of Go Well.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998.

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 Go Well 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 Go Well has some responsibility for ensuring data is collected, stored and handled appropriately.

Each member of Go Well that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

These people have key areas of responsibility:

• The board of directors is ultimately responsible for ensuring that Go Well meets its legal obligations.
• The manager, Sarah Price, is the Data Protection Officer and is responsible for keeping the board 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 subject access requests from individuals.
• Checking and approving any contracts or agreements with third parties that may handle sensitive data.
• Ensuring 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 third-party services used to store or process data, including cloud computing services.
• Approving any data protection statements attached to communications such as emails and letters.
• Addressing any data protection queries from journalists or media outlets.
• Working with other staff where necessary to ensure marketing initiatives abide by data protection principles.

Data Storage

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

When data is stored on paper, it will be kept in a secure place where unauthorised people cannot see it, including locked cupboards or filing cabinets in a secure storage room.

These guidelines also apply to data that is usually stored electronically but has been printed out:

• When not required, 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.
• 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:

• Multi-Factor Authentication should be set up in all Zoho accounts.
• Data will be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media such as CDs or DVDs, it will be kept locked away securely when not in use.
• Data will only be stored on designated drives and servers and uploaded only to an approved cloud computing service.
• Servers containing personal data will be kept in a secure location away from general office space.
• Data will be backed up frequently and backups will be tested regularly.
• Data should never be saved directly to unprotected or unencrypted laptops, tablets or smartphones.
• All servers and computers containing data should be protected by approved security software and a firewall.
• Data will be stored in clearly named files so documents can be found quickly when needed.
• Files containing data will only be accessible by relevant parties through private folders with limited access.
• Data will not be stored for longer than required by the project and will be reviewed annually.
• Any data no longer required will be disposed of in a secure manner.

Data Use

Personal data is of no value to Go Well 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, employees should ensure their computer screens are locked when left unattended.
• Personal data should not be shared informally and should never be sent by unsecured email.
• Data must be encrypted before being transferred electronically.
• Personal data should never be transferred outside of the European Economic Area.
• Employees should not save copies of personal data to their own computers and should always use the central copy.

Data Accuracy

The law requires Go Well to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that personal data is accurate, the greater the effort Go Well 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 and staff should not create unnecessary additional data sets.
• Staff should take every opportunity to ensure data is updated, for example by confirming a customer’s details when they call.
• Go Well will make it easy for data subjects to update the information held about them, for example via the company website.
• Data should be updated as inaccuracies are discovered.
• It is the manager’s responsibility to ensure databases are checked every six months.

Subject Access Requests

All individuals who are the subject of personal data held by Go Well 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 sarahprice@go-well.org. A standard request form can be supplied, although individuals do not have to use it.

Individuals will not be charged for subject access requests. The data controller will aim to provide the relevant data within 30 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Requests for the right to be forgotten or the right to rectification will be actioned and the results communicated to the relevant individual.

Disclosing Data for Other Reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Go Well will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the directors and the company’s legal advisers where necessary.

Providing Information

Go Well 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

To support this, the company has a privacy statement setting out how data relating to individuals is used by the company.

Data Breaches

In the case of a data breach, Go Well will inform any affected party or individual as soon as the breach is identified.

In cases involving an organisation or business, for example those using the Explore platform, Go Well will communicate directly with the organisation as directed by them and their reporting requirements. Go Well will co-operate fully in limiting the breach and supporting affected customers.

If a mobile device or ID badge is lost, this must be reported immediately to Sarah Price, CEO of Go Well.

Good Working Practice in Protecting Information