This is the Data Protection Policy for VendElectric. During normal business activities, VendElectric collects, stores and processes a variety of types of personal information. VendElectric recognises the need to treat such information in a secure and lawful manner.
VendElectric is committed to conducting its business in accordance with all applicable Data Protection laws and regulations, to being transparent about how it collects and uses the personal data of its employees, customers and clients, and to meeting its data protection obligations. This policy sets out VendElectric's commitment to data protection, and individual rights and obligations in relation to personal data.
This policy applies to all cases where VendElectric processes a data subject’s personal data either in electronic form or where it is held in manual files that are structured in a way that allows ready access to information about individuals. It applies to the personal data of job applicants, employees, clients and other personal data processed for business purposes.
VendElectric has appointed Robert Turner, Operations Director, as Data Protection Officer. He can be contacted at firstname.lastname@example.org. Questions about this policy, or requests for further information, should be directed to him.
Data Protection Principles
- personal data will be processed lawfully, fairly and in a transparent manner;
- personal data will be collected only for specified, explicit and legitimate purposes;
- personal data will be processed only where it is adequate, relevant and limited to what is necessary for the purposes of processing;
- personal data records will be kept accurate and up to date and all reasonable steps will be taken to ensure that inaccurate personal data is rectified or deleted without delay;
- personal data will be retained only for the period necessary for processing. The periods for which VendElectric holds personal data are contained in its privacy notices to individuals.
- appropriate measures will be adopted to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.
VendElectric keeps a record of its processing activities in respect of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).
Subject Access Requests
- whether his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
- to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
- for how long his/her personal data is stored (or how that period is decided);
- his/her rights to rectification or erasure of data, or to restrict or object to processing;
- his/her right to complain to the Information Commissioner if he/she thinks VendElectric has failed to comply with his/her data protection rights; and
- whether VendElectric carries out automated decision-making and the logic involved in any such decision-making.
To make a subject access request, the individual should follow the instructions in the associated privacy notices. In some cases, VendElectric may need to ask for proof of identification before the request can be processed. VendElectric will inform the individual if it needs to verify his/her identity and the documents it requires.
VendElectric will normally respond to a request within a period of one month from the date it is received. In some cases, such as where VendElectric processes large amounts of the individual's data, it may respond within three months of the date the request is received. VendElectric will write to the individual within one month of receiving the original request to tell him/her if this is the case.
If a subject access request is manifestly unfounded or excessive, VendElectric is not obliged to comply with it. Alternatively, VendElectric may agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. If an individual submits a request that is unfounded or excessive, VendElectric will notify him/her that this is the case and whether it will respond to it.
Other Individual Rights
- rectify inaccurate data;
- stop processing or erase data that is no longer necessary for the purposes of processing;
- stop processing or erase data if the individual's interests override VendElectric's legitimate grounds for processing data (where VendElectric relies on its legitimate interests as a reason for processing data);
- stop processing or erase data if processing is unlawful; and
- stop processing data for a period if data is inaccurate or if there is a dispute about whether the individual's interests override VendElectric's legitimate grounds for processing data.
Where VendElectric engages third parties to process personal data on its behalf, such parties do so based on written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data in line with prevailing data protection legislation and guidance from the Information Commissioner.
VendElectric entity will enter into an adequate processing agreement with the third party. The agreement must require the data processor to protect the personal data from further disclosure and to only process personal data in compliance with VendElectric instructions. In addition, the data processor will be required to implement appropriate technical and organisational measures to protect the personal data, procedures for providing notification of personal data breaches, and submit to audits and inspections by the data controller.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.
Individuals may have access to the personal data of other individuals, customers and clients during their employment. Where this is the case, VendElectric relies on individuals to help meet its data protection obligations.
Individuals who have access to personal data are required:
- to access only data that they have authority to access and only for authorised purposes;
- not to disclose data except to individuals (whether inside or outside VendElectric) who have appropriate authorisation;
- to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
- not to remove personal data, or devices containing or that can be used to access personal data, from VendElectric's premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device; and
- not to store personal data on local drives or on personal devices that are used for work purposes.
Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under VendElectric's disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal.
Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.