Data protection law

The Data Protection Act 2018 describes how organisations – including The Pantry Catering UK Limited – must collect, handle and stores personal information.
These rules apply regardless 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:

• Be processed fairly and lawfully
• Be obtained only for specific, lawful purposes
• Be adequate, relevant and not excessive
• Be accurate and kept up to date
• Not be held for any longer than necessary
• Processed in accordance with the rights of data subjects
• Be protected in appropriate ways
• Not be transferred outside the European Economic Area (EEA), unless that country or territory also requires an adequate level of protection.

People, risks and responsibilities

Policy scope

This policy applies to:

• The head office of The Pantry Catering UK Limited
• All branches of The Pantry Catering UK Limited
• All staff and volunteers of The Pantry Catering UK Limited
• All contractors, suppliers and other people working on behalf of The Pantry Catering UK Limited

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 2018. 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 The Pantry Catering UK Limited from very real data security risks these include:

• 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.

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 board of directors is ultimately responsible for ensuring that The Pantry Catering UK Limited meets its legal obligations.
• The data protection officer Anthony Wright is responsible for:
• Keeping all relevant departments updated about data protection responsibilities, risks and issues.
• Reviewing all data protection procedures and related policies, in line with an agreed schedule.
• Arranging data protection training and advice for the people covered in this policy.
• Handling data protection questions from staff and anyone else covered by this policy.
• Dealing with requests from individuals to see the data The Pantry Catering UK Limited holds about them (also called 'subject access requests').
• ◦Checking and approving any contracts or agreements any contracts or agreements with third parties that may handle the companies sensitive data.
• The IT Manager (Anthony Wright), is responsible for:
  • Ensuring all system, services and equipment used for storing data meet acceptable security standards.
  • Performing regular checks and scans to ensure security hardware and software is functioning properly.
  • Evaluating any third-party service's the company is considering using to store or process data. For instance, cloud computing services.
• The Marketing Manager (Anthony Wright), is responsible for:
  • Approving any data protection statements attached to communications such as emails and letters.
  • Addressing any data protection queries from journalists or media outlets like newspapers etc.
  • Where necessary, working with other staff to ensure marketing initiatives abide by data protection     principles.

General staff guidelines

• The only people able to access 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.
• The Pantry Catering UK Limited 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 or 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 cabnet.
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
• 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 drivers 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.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data should be protected by approved security software and firewall.

Data use

Personal data is of no value to The Pantry Catering UK Limited 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.
• Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
• Personal data should never be transferred outside of the European Economic Area.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data

Data accuracy

The law requires The Pantry Catering UK Limited 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 The Pantry Catering UK Limited 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.
• The Pantry Catering UK Limited will make it easy for data subjects to update the information The Pantry Catering UK Limited holds about them. For instance, via the website.
• 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.
• It is the marketing Manager's responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject access requests

All individuals who are the subject of personal data held by The Pantry Catering UK limited 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's 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 at awright@thepantrycatering.co.uk . The data controller can supply a standard request form although individuals do not have to use this.

The data controller will always verify the identity of anyone making a subject access request before handing any information over.

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 The Pantry Catering UK Limited will disclose requested data. However the data controller will ensure the request is legitimate, seeking assistance from the company's legal advisers where necessary.

Providing information

The Pantry UK Limited 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.)