Nationwide Hazardous Management

GDPR Policy

Statement of Policy

The company is committed to the principle to ensure compliance with the General Data Protection Act (Regulation (EU) 2016/679) and to ensure that Woods Building Services Ltd t/a AA Woods discharges all of its legal obligations in this respect. The General Data Protection Regulation (GDPR) will apply in the UK from 25 May 2018. AA Woods is required to process relevant personal data regarding members of staff, applicants and their siblings, alumni and customers as part of its operation and shall take all reasonable steps to do so in accordance with this policy.

Principles of the General Data Protection Regulation (GDPR)

The Company shall so far as is reasonably practicable comply with the General Data Protection Principles contained in the Data Protection regulation to ensure all data is;

  • processed lawfully, fairly and in a transparent manner in relation to individuals
  • collected for specified, explicit and 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 purposes or statistical purposes shall not be considered to be incompatible 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 ensure that personal data that is inaccurate, having regard to the purposes for which they are processed are erased or rectified without delay
  • kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals
  • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures

General provisions

  • This policy applies to all personal data processed by AA Woods
  • The Responsible Person shall take responsibility for AA Woods’ ongoing compliance with this policy
  • This policy shall be reviewed at least annually
  • Woods has registered with the Information Commissioner’s Office as an organisation that processes personal data. ICO Reference number Z2835228

Lawful, fair and transparent processing

  • To ensure its processing of data is lawful, fair and transparent, AA Woods shall maintain a Register of Systems
  • The Register of Systems shall be reviewed at least annually
  • Individuals have the right to access their personal data and any such requests made to AA Woods shall be dealt with in a timely manner 

Lawful purposes

  • All data processed by AA Woods must be done on one of the following lawful basis: consent, contract, legal obligation, vital interests, public task or legitimate interests
  • AA Woods shall note the appropriate lawful basis in the Register of Systems
  • Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data
  • Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in AA Woods’ systems

Data minimisation

  • AA Woods shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed

Accuracy

  • AA Woods shall take reasonable steps to ensure personal data is accurate
  • Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date

Archiving / removal

  • To ensure that personal data is kept for no longer than necessary, AA Woods shall put in place an archiving policy for each area in which personal data is processed and reviewed annually. QMF0181 – Archiving records retention list
  • The archiving policy shall consider what data should / must be retained, for how long, and why

Security

  • AA Woods shall ensure that personal data is stored securely using modern software that is kept-up-to-date
  • Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information
  • When personal data is deleted this should be carried out safely such that the data is irrecoverable
  • All data on the ‘N’ drive is automatically backed-up daily to an off-site facility for disaster recovery solutions, with a back-up manually taken on site by the Compliance Manager at least on a weekly basis

Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, AA Woods shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO and the clients whose data has been affected.