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WHITTLES JEWELLERS DATA PROTECTION POLICY CONTEXT AND OVERVIEW

Introduction
Whittles Jewellers needs to gather and use certain information about individuals.

These can include clients, business contacts, employees and other people with whom Whittles Jewellers has a relationship and whom it 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 comply with the law.

Why this policy exists
This Data Protection Policy ensures that Whittles Jewellers:
• Complies with data protection law and follows good practice
• Protects the rights of staff, clients 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 General Data Protection Regulations (GDPR) 2018 describe how organisations – including Whittles Jewellers – must collect, handle and store personal information.

These regulations 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 2018 is underpinned by six important principles. Personal data must be:
• Processed lawfully, fairly and in a transparent manner
• Collected for specified, explicit and legitimate purposes
• Adequate, relevant and limited to what is necessary
• Accurate and, where necessary, kept up to date
• Retained only for as long as necessary

21 May 2018

Processed in an appropriate manner to maintain security

PEOPLE, RISKS AND RESPONSIBILITIES

Policy scope
This policy applies to all Whittles Jewellers staff

This policy applies to all data that Whittles Jewellers holds relating to identifiable individuals. 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 Whittles Jewellers from 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 Whittles Jewellers uses data relating to them.

Reputational damage – for instance, Whittles Jewellers could suffer if hackers successfully gained access to personal data.

Responsibilities
Everyone working for Whittles Jewellers has some responsibility for ensuring data is collected, stored and handled properly in line with this policy and data protection principles.

The Director is responsible for ensuring that Whittles Jewellers meets its legal obligations.

This includes:
Reviewing all data protection procedures and related policies, in line with an agreed schedule

Arranging data protection training and advice

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

Dealing with requests from individuals to see the data that Whittles Jewellers holds about them (Subject Access Requests)

Checking and approving any contracts or agreements with third parties that may handle Whittles Jewellers personal data

Ensuring all IT systems, services and equipment used for storing data meet acceptable security standards

21 May 2018

Performing regular checks and scans to ensure security hardware and software is functioning properly

Evaluating any third party services Whittles Jewellers is considering using to store or process data, such as cloud computing services Approving any data protection statements attached to communications

GENERAL GUIDELINES
Whittles Jewellers will provide training to staff to help them understand their responsibilities when handling data.

All data must be kept secure by taking sensible precautions and following the guidelines below.

Strong passwords must be used on all systems.

Personal data should not be disclosed to unauthorised people outside Whittles Jewellers.

Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted.

Staff should request help the Director if they are unsure of any aspect of data protection.

DATA STORAGE
These rules describe how and where data should be safely stored.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it. Data print-outs 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. If data is stored on removable media, these should be locked away securely when not being used.

Data should only be stored on designated drives and servers, and should only be uploaded to approved cloud computing services.
Data should be backed up frequently. These backups should be tested regularly.

All servers and computers containing data should be protected by approved security software and a firewall.

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DATA ACCURACY
The Regulations require Whittles Jewellers to take reasonable steps to ensure data is accurate and kept up to date. It is the responsibility of all staff implement this. Data should be kept in as few places as necessary. Staff should not create any unnecessary additional data sets.

SUBJECT ACCESS REQUESTS
All individuals whose personal data is held by Whittles Jewellers are entitled to:
• Ask what information Whittles Jewellers holds about them and why
• Ask how to gain access to it
• Be informed how to keep it up to date
• Be informed how Whittles Jewellers is meeting its data protection obligations
• Access requests from individuals should be made by email, addressed to
enquiries@whittlesjewellers.co.uk

DISCLOSING DATA FOR OTHER REASONS
In certain circumstances, GDPR 2018 allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances Whittles Jewellers will disclose such data in response to a proven legitimate request, seeking assistance from the Company’s legal advisors where necessary.

21 May 2018