Privacy Policy

Data protection policy:
Reen Manor Riding Stables
Context and overview
Key details
Policy prepared by: Carole Opie
Next review date: 26th May 2019
Introduction
Reen Manor Riding Stables needs to gather and use certain information
about individuals in order to communicate with them
These can include visitors, 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 Reen Manor Riding StablesComplies with data protection law and follow good practice
Protects the rights of staff, members and visitors
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 describes how organisations — including Reen Manor Riding Stables— 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 Act 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:
All staff at the Reen Manor Riding Stables
All contractors, suppliers and other people working on behalf of Reen Manor Riding Stables
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. However our system which holds data is not connected to the internet. The email addresses are the only item at risk of hackers but the computers are passworded and have firewalls. The information held includes:
Names of individuals
Postal addresses – both home and business
Email addresses
Telephone numbers
Data protection risks
This policy helps to protect Reen Manor Riding Stables 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 Reen Manor Riding Stables 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.
However, these people have key areas of responsibility:
The Directors are ultimately responsible for ensuring the Reen Manor Riding Stables meets its legal obligations.
The proprietor Carole Opie, is responsible for:
o Keeping the board updated about data protection responsibilities,
risks and issues.
o Reviewing all data protection procedures and related policies, in
line with an agreed schedule.
o Arranging data protection training and advice for the people
covered by this policy.
o Handling data protection questions from staff and anyone else
covered by this policy.
o Dealing with requests from individuals to see the data Reen Manor Riding Stables holds about them (also called ‘subject
access requests’).
o Checking and approving any contracts or agreements with third
parties that may handle the company’s sensitive data.
o Ensuring all systems, services and equipment used for storing
data meet acceptable security standards.
o Performing regular checks and scans to ensure security hardware
and software is functioning properly.
o Evaluating any third-party services the company is considering
using to store or process data. For instance, cloud computing
services.
o Approving any data protection statements attached to communications
such as emails and letters.
o Where necessary, working with other staff to ensure marketing
initiatives abide by data protection principles.
General staff guidelines
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. When access to confidential
information is required, employees can request it from their line managers.
We 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.
In particular, strong passwords must be used and they should never
be shared.
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.
Employees should request help from their line manager or the data
protection officer if they are unsure about any aspect of data protection.
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.
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:
Data should be protected by strong passwords that are changed
regularly and never shared between employees.
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, in line with the company’s standard backup procedures.
All servers and computers containing data should be protected by approved
security software and a firewall.
Data use
Personal data is of no value to the Reen Manor Riding Stables 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 the
screens of their computers are always locked when left unattended.
Personal data should not be shared informally. In particular, it should
never be sent by email, as this form of communication is not secure.
Where possible, data will be encrypted before being transferred
electronically.
Personal data should never be transferred outside of the European
Economic Area.
Data accuracy
The law requires Reen Manor Riding Stables 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 Reen Manor Riding Stables 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.
Reen Manor Riding Stables will make it easy for data subjects
to update the information Reen Manor Riding Stables.
holds about them. This can be done by contacting Carole Opie via info@reenstables.com
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.
Subject access requests
All individuals who are the subject of personal data held by Reen Manor Riding Stables 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 contact 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 Carole Opie via info@reenmanorstables.com
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, Reen Manor Riding Stables will disclose
requested data. However, the data controller will ensure the request is legitimate,
seeking assistance from the Directors and from the company’s legal advisers
where necessary.
Making a Complaint
If you feel that your data has been used incorrectly and without your permission,
you should first make a complaint in writing to our info@rosemundy.co.uk
If you feel that your complaint has not been handled correctly by Reen Manor Riding Stables you have a right to make a further complaint to the
Information Commissioners Office ( ICO ) https://ico.org.uk/ who have legal
oversight of the GDPR regulations in the UK.
Providing information
Reen Manor Riding Stables 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 these ends, the company has a privacy statement, setting out how data
relating to individuals is used by the company.
[This is available on request. A version of this statement is also available on
the company’s website – www.reenmanorstables.com