Company Number 0773 7680. ICO notification number ZA289121

Purpose

Crafnant Consulting is committed to being transparent about how it collects and uses the personal data of its clients, its clients’ employees and any third parties which it works with and to meeting its data protection obligations. This policy sets out Crafnant Consulting’s commitment to data protection, and individual rights and obligations in relation to personal data.

This policy applies to the personal data of:

  • Crafnant Consulting clients both past, present and prospective, referred to as Client-related personal data
  • job applicants, employees, workers, contractors, volunteers, interns, apprentices and former employees of Crafnant Consulting clients’, referred to as HR-related personal data.

Crafnant Consulting has appointed Tracy Madgwick as the person with responsibility for data protection compliance within Crafnant Consulting. She can be contacted at tracy@crafnantconsulting.co.uk Questions about this policy, or requests for further information, should be directed to her.

Definitions

“Personal data” is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.

Data protection principles

Crafnant Consulting processes client-related and HR-related personal data in accordance with the following data protection principles:

  • Crafnant Consulting processes personal data lawfully, fairly and in a transparent manner.
  • Crafnant Consulting collects personal data only for specified, explicit and legitimate purposes.
  • Crafnant Consulting processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
  • Crafnant Consulting keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
  • Crafnant Consulting keeps personal data only for the period necessary for processing.
  • Crafnant Consulting adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

Crafnant Consulting tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons.

Where Crafnant Consulting processes special categories of HR-related personal data on behalf of a client, it does so to enable the client to carry out its obligations and to exercise its rights in the field of employment law.

Crafnant Consulting will update personal data promptly if an individual advises that his/her information has changed or is inaccurate.

Personal data gathered during the relationship with the client is held in a dedicated electronic client file and on Crafnant Consulting’s email systems. The periods for which Crafnant Consulting holds client-related and HR-related personal data are contained in its privacy notices to clients.

Crafnant Consulting keeps a record of its processing activities in respect of client-related and HR-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

Individual rights

As a data subject, individuals have a number of rights in relation to their personal data.

Subject access requests

Individuals have the right to make a subject access request. If an individual makes a subject access request, Crafnant Consulting will tell him/her:

  • whether or not 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 Crafnant Consulting has failed to comply with his/her data protection rights; and
  • whether or not Crafnant Consulting carries out automated decision-making and the logic involved in any such decision-making

Crafnant Consulting will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.

If the individual wants additional copies, Crafnant Consulting will charge a fee, which will be based on the administrative cost to Crafnant Consulting of providing the additional copies.

To make a subject access request, the individual should send the request to tracy@crafnantconsulting.co.uk. In some cases, Crafnant Consulting may need to ask for proof of identification before the request can be processed. Crafnant Consulting will inform the individual if it needs to verify his/her identity and the documents it requires.

Crafnant Consulting will normally respond to a request as soon as possible and certainly within a period of one month from the date the request is received.

If a subject access request is manifestly unfounded or excessive, Crafnant Consulting is not obliged to comply with it. Alternatively, Crafnant Consulting can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which Crafnant Consulting has already responded. If an individual submits a request that is unfounded or excessive, Crafnant Consulting will notify him/her that this is the case and whether or not it will respond to it.

Other rights

Individuals have a number of other rights in relation to their personal data. They can require Crafnant Consulting to:

  • 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 Crafnant Consulting’s legitimate grounds for processing data (where Crafnant Consulting 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 or not the individual’s interests override Crafnant Consulting’s legitimate grounds for processing data.

To ask Crafnant Consulting to take any of these steps, the individual should send the request to tracy@crafnantconsulting.co.uk

Data security

Crafnant Consulting takes the security of client-related and HR-related personal data seriously. Crafnant Consulting has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure.  All personal data is stored on a computer which is password protected and encrypted with Bitlocker using 128-bit AES encryption.

Where Crafnant Consulting engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

Impact assessments

Some of the processing that Crafnant Consulting carries out may result in risks to privacy. Where processing would result in a high risk to individual’s rights and freedoms, Crafnant Consulting will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

Data breaches

If Crafnant Consulting discovers that there has been a breach of client or HR-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. Crafnant Consulting will record all data breaches regardless of their effect.

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.

International data transfers

Crafnant Consulting does not transfer data to countries outside the EEA.

Client responsibilities

Clients are responsible for helping Crafnant Consulting keep their own personal data up to date. Clients are also responsible for helping Crafnant Consulting keep HR-related data for their business up to date. Clients should let Crafnant Consulting know if data provided to Crafnant Consulting changes.

Associate responsibilities

From time to time, Crafnant Consultant may work with associates who may have access to client-related and HR-related personal data in the course of their work with Crafnant Consulting.  Where this is the case, Crafnant Consulting relies on those associates to help meet its data protection obligations to clients and the employees, or workers of that client.

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 Crafnant Consulting) 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);

Failure to follow these requirements will result Crafnant Consulting ending the relationship with that associate.

Training

Crafnant Consulting will provide training to all associates about their data protection responsibilities as part of any induction process.

Review of this policy

This policy will be reviewed at least annually. The next review date is February 2019. It may be reviewed earlier than this date in light of the amendments to the Data Protection Act 2018.

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