Data Protection Policy
Effective Date: January 2019 Version: 1.0
Who are "We"/"Us"
Mind Evolution Ltd is registered with the Company House in England - Company Number: 09513266. “We” deliver personal development services, and are located in Bracknell -Berkshire.
Our Website address is: https://mindevolution.co.uk
For any Data or Privacy enquiries please contact us:
Email: firstname.lastname@example.org or
Phone: +44(0)1344 935 357
The Data Protection Policy of our Company and Website.
“We” or “Us” (Mind Evolution Ltd) sometimes collect and use specific personal data and information about individuals. These individuals can include customers, suppliers, business contacts, employees, and other people with whom “We” have a relationship with or may need to contact.
This policy describes how these personal data must be collected, processed, and stored to meet data protection standards and comply with the law.
The reasons for having this policy
This data protection policy describes how “We”:
- comply with data protection laws and follows good practice
- protects the rights of employees, partners, customers, and contractors
- store and process individuals’ data
- helps protect personal data from the risks of a data breach
Data protection laws
“We” are committed to processing data following the General Data Protection Regulation (GDPR) and other data protection and privacy laws. These data protection and privacy laws describe how organisations including “Us” must collect, process, and store personal information. These rules apply regardless of whether data are stored electronically, on paper, or in other formats. To comply with the law and the regulations, personal information must be collected and used fairly, stored safely, and not disclosed unlawfully.
Article 5 of the GDPR requires that personal data will be:
- processed lawfully, fairly, and transparently in relation to individuals
- collected for specified, explicit, 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, or statistical purposes will be considered compatible with the initial purposes
- adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed
- accurate and, where necessary, kept up to date; every reasonable step must be taken to make sure that personal data that are inaccurate with regard to the purposes for which they are processed, are immediately erased or rectified
- 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 in the public interest, scientific or historical research, or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals
- processed in a manner that ensures organisations security of the personal data, including protection against unauthorized or unlawful processing; accidental loss, destruction, or damage; using appropriate technical or organizational measures.
People, risks, responsibilities, and policy scope
This policy applies to:
- all offices of Mind Evolution Ltd
- all employees of Mind Evolution Ltd
- all suppliers, contractors, and other people working on behalf of
Mind Evolution Ltd.
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside some privacy and data protection laws. This includes and not limited to the following personal data:
- names of individuals
- postal addresses
- email addresses
- telephone numbers
- other personal information about individuals.
Data protection risks
This policy helps to protect “Us” from data security risks, including:
- breaches of confidentiality, for example, information being given out or exposed without proper authorisation
- failing to give choice, for example, all individuals should be free to choose how the company uses data relating to them
- reputational damage, for example, the company could suffer if unauthorised individuals successfully gained access to sensitive data.
Everyone who works for on behalf or with Mind Evolution Ltd has some responsibility for making sure that data are collected, stored, and processed appropriately. Each individual who handles personal data must make sure that the data are handled and processed in line with this policy and the principles of data protection.
People with key areas of responsibility:
The board of directors is ultimately responsible for making sure that Mind Evolution Ltd meets its legal obligations about data protection laws including but not limited to:
- Keeping updated about data protection laws, responsibilities, risks, and issues
- Reviewing all data protection procedures and related policies periodically
- Providing data protection training and advice to people covered by this policy
- Responding to data protection questions from staff and anyone else covered by this policy
- Responding to requests from individuals to see the data “We” hold about them
- Reviewing and approving any agreements or contracts with third parties that may process the company’s personal and sensitive data.
- Making sure that all computer and electronic systems, services, and equipment used for storing and processing data meet acceptable security standards
- Performing regular security checks and scans to make sure that hardware and software is functioning properly
- Evaluating any third-party services that the company is considering using to collect, process, or store data.
- Approving any data protection statements attached to communications such as emails and letters
- addressing data protection queries from journalists or the media
- Where necessary, working with other employees to make sure that marketing initiatives adhere to the principles of data protection.
Employees and Coaching Assistants 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 with others in any circumstances. When access to data and the sharing of confidential information is required by law, an authorisation from the Board of Directors must be obtained.
- Training will be provided to all employees and Coaching Assistants to help them understand their responsibilities when handling data and confidential information.
- Employees and Coaching Assistants should keep all data secure by taking reasonable precautions and following the guidelines below.
- Strong passwords must be used and should never be shared.
- Personal data should not be disclosed to unauthorised people within the company nor externally.
- Data should be regularly reviewed and updated if they are found to be out of date. If no longer required, they should be deleted and disposed of using appropriate security procedures.
- Employees should request help from the Board of Directors if they are unsure about any aspect of data protection procedures.
- Personal data should not be obtained for personal benefit and without consent from the individual in question.
- These rules describe how and where personal data should be safely stored.
- When personal data is stored on paper, it should be kept in a secure place where unauthorised people cannot see them.
- These guidelines also apply to personal data that is usually stored electronically but have been printed out for some reason.
- When not required, the paper or files should be kept in a locked drawer, filing cabinet, or securely destroyed.
- Employees and contractors should make sure that paper and printouts are not left where unauthorised people could see them, such as in copiers or printers.
- Printouts of personal data should be shredded and disposed of securely when no longer needed.
- When data are stored electronically, they must be protected from unauthorised access, accidental deletion, and malicious hacking attempts.
- Personal data should be protected by strong passwords that are changed regularly and never shared among employees nor contractors.
- If personal data are stored on removable media such as a DVD, CD, or portable drive, they should be kept locked away securely when not used.
- Personal data should only be stored on designated drives and servers and should only be uploaded to approved and secure cloud computing services.
- Servers containing personal data should be situated in a secure location.
- All data should be backed up frequently and securely. Backups should regularly be tested in line with the company’s standard backup procedures.
- Personal data should never be saved directly to laptops, portable drives, tablets, nor smartphones.
- All computers and servers containing personal data should be protected by approved firewall and security software.
Personal data use
When personal data are accessed, is at the highest risk of theft, loss, or corruption:
- When working with personal data, Employees, Coaching Assistants, Contractors, and others should make sure that their computers are always password protected and locked when left unattended.
- Personal data should not be shared with anyone who is not authorised to see them. Unless encrypted, they should never be sent by email, as most email communication is not secure.
- Data must be encrypted before being transferred electronically.
- Personal data should never be transferred out of the European Union without appropriate consent, binding corporate rules, compelling legitimate interests, specific derogations, or other approved processes.
- Employees, contractors, and others should not save copies of personal data to their computers or other devices. Always access and update the central copy of any personal data.
Personal data accuracy
- The law requires that “We” take reasonable steps to make sure that personal data are kept accurate and up to date.
- The more important it is that the personal data are accurate, “We” put effort into guaranteeing the accuracy of it.
- It is the responsibility of all employees, contractors, and others who work with personal data to take reasonable steps to keep personal data as accurate and up to date as possible.
- Personal data is held in as few places as necessary. Company employees and contractors should not create unnecessary additional data sets.
- Company employees and contractors should take every opportunity to make sure that data is updated, e.g. by confirming customers information when they call.
- Make it easy for data subjects to update the information “We” hold about them. e.g. by using the website, or by phone.
- Personal data should be updated when inaccuracies are discovered. e.g. if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
- Make sure that marketing databases are checked and updated annually.
Subject access requests
All individuals who are the subjects of personal data held by “Us” are entitled to:
- ask what information the “We” hold about them and why
- ask how to gain access to it
- know how to keep it up to date
- know how the company is meeting its data protection obligations.
Any individual can contact “Us” requesting this information, by writing to email@example.com.
“We” will provide the relevant data within 30 days from receiving the request. “We” will always verify the identity of anyone making such access request before providing them with any information.
Disclosing personal data for other reasons
In certain circumstances privacy laws allow personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, “We” will disclose the requested data to the requesting agency. However, “We” will make sure that the request is legitimate and seek legal assistance if necessary.
In the event of a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data the We will assess the risk to people’s rights and freedoms and if required report this breach to the appropriate authority.
“We” will as reasonably practicable make sure that all individuals are made aware that their data are being processed, and that they understand:
- how their personal data is being used
- how to exercise their rights under the law.
Email: firstname.lastname@example.org or
Phone: +44(0)1344 935 357