Privacy & Terms

INTRODUCTION

 

The Clearance Crew, as an operational need for its business, needs to gather, use, and retain certain information about individuals who have either transacted with The Clearance Crew or shown an interest in what The Clearance Crew does. These can include: customers, suppliers, business contacts, previous customers, employees, and other individuals who have an interest in The Clearance Crew and whom the company may need to make contact with during the course of its business.

This policy describes how this personal data will be collected, handled, and stored, and for how long it will be kept, in order to strictly comply with the company’s own policy and data protection standards – and to comply with the law.

 

WHY THIS POLICY EXISTS

 

This Data Protection Policy exists to ensure that The Clearance Crew:

• Complies with Data Protection laws and follows good practice.

• Protects the rights of employees, customers, and suppliers.

• Is transparent about how it stores, processes, and disposes of personal information and data.

• Protects itself from the risk of breaches of data security.

 

DATA PROTECTION LAW

 

The Data Protection Act 1998 proscribes how organizations (including The Clearance Crew) must collect, protect, and store personal information held on individuals. These rules must be adhered to regardless of how the data is stored, e.g., electronically, on paper, or digitally. To comply with the law, data must be collected and processed fairly, stored securely, and not disclosed unlawfully.

The Data Protection Act is underpinned by eight guiding principles. Data must:

1. Be processed lawfully and fairly.

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. Be processed in accordance with the rights of Data Subjects.

7. Be protected in appropriate ways.

8. Not be transferred outside of the European Economic Area (EEA), unless that country or territory also ensures adequate levels of protection.

 

PEOPLE, RISKS AND RESPONSIBILITIES

POLICY SCOPE

 

This Policy applies to:

• The Head Office of The Clearance Crew.

• All employees and staff of The Clearance Crew.

• Contractors, sub-contractors, and suppliers to The Clearance Crew and any other persons working on behalf of The Clearance Crew.

It applies to all data held by The Clearance Crew relating to identifiable individuals, even if that data technically falls outside of the scope of the Data Protection Act 1998. This will include:

• Names of individuals.

• Postal Addresses.

• E-mail addresses.

• Telephone Numbers.

• Any other information relating to individuals.

 

DATA PROTECTION RISKS

 

This policy helps to protect The Clearance Crew from data security risks, including:

• Breaches of Confidentiality – For instance, names and addresses being given out inappropriately.

• Failing to Offer Choice – For instance, all individuals should be free to choose how the company treats data relating to them.

• Reputational Damage – For instance, the company could suffer if hackers successfully gained access to sensitive data.

 

RESPONSIBILITIES

 

Everybody who works for, or with, The Clearance Crew has a responsibility for ensuring that data is collected, processed, and stored appropriately. Each Team that handles personal data must ensure that it is collected, processed, and stored in compliance with this policy and The Eight Data Protection Principles.

However, there are key areas of responsibility:

The Directors are ultimately responsible for ensuring that The Clearance Crew meets its legal obligations.

The Data Protection Officer is responsible for:

• Keeping the Directors updated about Data Protection responsibilities, risks, and issues.

• Reviewing all Data Protection Policies and Procedures in line with the prescribed schedule.

• Arranging Data Protection training and advice for all staff covered by this policy.

• Handling Data Protection questions and queries from all people covered by this policy.

• Dealing with requests from individuals to witness the Data that The Clearance Crew holds about them (also called, “Subject Access Requests”).

• Checking and approving any contracts or agreements made with third parties that may process The Clearance Crew's sensitive data.

The Information Technology Manager is responsible for:

• Ensuring that all systems, services, and equipment used for storing personal information meet acceptable security standards.

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

• Evaluating third-party services which The Clearance Crew already use or are contemplating using to store or process data.

The Director is responsible for:

• Approving all data protection statements attached to communications issued by The Clearance Crew.

• Addressing any Data Protection enquiries from the media or professional bodies.

• Working with other staff and contractors to ensure that Marketing Programmes abide by the Eight Data Protection Principles.

 

GENERAL STAFF GUIDELINES

 

• The only people able to access personal data covered by this policy will be those who need to do so as part of their work.

• Data MUST NOT be shared informally. When access to confidential information is required by staff, a request must be made, in the first instance, to their line manager.

• The Clearance Crew will provide training to all of those working for, and with, it to help them understand their responsibilities in handling data covered by this policy.

• Employees must keep all data secure by taking sensible precautions and by following the following guidelines:​​

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  • Staff WILL request help and assistance from the Data Protection Officer if they are unsure about any aspect of Data Protection.

• Data WILL BE regularly reviewed and updated, and when found to be out of date or no longer required WILL BE deleted and disposed of by following secure procedures.

• Personal Data WILL NOT be disclosed to unauthorized persons, either within or external to the company.

 

DATA STORAGE

 

These rules describe how and where data will be safely stored. Questions about the safe storage of data will be referred to the Director.

Where data is stored on paper, it will be kept secure and out of view and access from unauthorized staff. This applies also to data that is normally stored electronically but has been printed.

• When not being processed, the data must be kept in a locked cupboard, drawer, or filing cabinet.

• Staff WILL ensure that paper and printouts are not left in any place where they can be viewed by unauthorized personnel.

• Data held on paper and printouts MUST be destroyed by shredding once they have become obsolete or no longer required.

When Data is stored electronically, it MUST be protected from being viewed or accessed by unauthorized personnel, being accidentally deleted, or maliciously hacked:

• Access to computer systems and hardware where data is stored will be protected by strong passwords which are never shared and changed often.

• Where data is stored on removable media (e.g., DVD), this must be stored securely in locked cupboards, drawers, or filing cabinets when not being used.

• Data must only be stored on designated devices and drivers and will only be uploaded to an approved cloud computing service.

• Servers containing Personal Data should be sited in a secure location and away from general open access office facilities.

• Data WILL be backed up frequently and, in line with company back-up procedures and schedules, tested regularly.

• Data WILL NOT be saved directly to laptops or other mobile devices.

• All servers and computers storing Personal Data will be protected by approved security software and a firewall.

 

DATA USE

 

Personal Data is of no use to The Clearance Crew unless the business can make use of it. However, it is when Personal Data is in use that the greatest risks occur that can result in data being corrupted, hacked, or lost or stolen:

• When working with Personal Data, staff must ensure that computer screens are locked when they are not in attendance.

• Personal Data will not be shared informally. It should not be sent by e-mail, as this form of communication is not secure.

• Personal Data will be encrypted before being transferred electronically. The Information Technology Manager will advise on sending data to authorized third external contacts.

• Personal Data will never be transferred outside of the European Economic Area.

• Staff will not save Personal Data to their personal laptops or mobile devices. Personal Data will be kept and updated on central copies.

 

DATA ACCURACY

 

The law requires that The Clearance Crew take reasonable steps to keep data accurate and up to date. The more important it is that the Personal Data is up to date, the more important it is for The Clearance Crew to ensure its accuracy.

It is the responsibility of all staff that has access to Personal Data to take reasonable steps to ensure that it is kept accurate and up to date.

• Data will be kept in as few places as necessary. Staff will not create any unnecessary data sets.

• Staff will take every opportunity to ensure that data is kept accurate and up to date, for example, by confirming a customer’s details during an incoming phone call.

• The Clearance Crew will make it easy for Data Subjects to update the information that The Clearance Crewholds on them, for instance, by using the Contact Us form on the website.

• Data should be updated as soon as an inaccuracy is discovered. For instance, if a customer cannot be reached on the telephone number stored, then that number should be removed from the data set.

 

SUBJECT ACCESS REQUESTS

 

All individuals who are the subject of Personal Data held by The Clearance Crew are entitled to:

• Ask what information is held by The Clearance Crew and for what reason/purpose.

• Ask how to gain access to that data.

• Be informed on how to keep the data up to date.

• Be informed how The Clearance Crew is meeting its Data Protection obligations.

If an individual makes contact with the company requesting this information, it is called a Data Access Request.

Subject Access Requests will be made to the Director of The Clearance Crew. The Director can supply a standard Request Form, although individuals do not have to use this form.

The Director will always verify the identity of anyone making a Subject Access Request before passing on any information.

 

 

DISCLOSING DATA FOR ANY OTHER REASON

 

In certain circumstances, the Data Protection Act allows for Personal Data to be disclosed to Law Enforcement Agencies without the consent of the Data Subject.

 

Under these circumstances, The Clearance Crew will disclose the requested data. However, the Data Protection Officer will ensure that the request is legitimate, seeking advice from the Director and the Company’s legal advisors where necessary.

 

 

PROVIDING INFORMATION

 

The Clearance Crew 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 statement is available on request and is also available on the company’s website.