Data Protection Policy (GDPR / Compliant)
Aim and Scope of Policy
This policy applies to the processing of personal data in manual and electronic records kept by A J Events Services. It covers A J Events Service's response to any data breach and other rights under the General Data Protection Regulation.
This policy applies to the personal data of clients, existing and former employees, apprentices, volunteers, placement students, workers and self-employed contractors. These are referred to in this policy as relevant individuals.
“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.
“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).
“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.
“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
A J Events Services makes a commitment to ensuring that personal data, including special categories of personal data and criminal offence data (where appropriate) is processed in line with GDPR and domestic laws and all its customers and employees conduct themselves in line with this, and other related policies. Where third parties process data on behalf of A J Events Services, A J Events Services will ensure that the third party takes such measures in order to maintain A J Events Services’s commitment to protecting data. In line with GDPR, A J Events Services understands that it will be accountable for the processing, management and regulation, and storage and retention of all personal data held in the form of manual records and on computers.
Types of Data Held
Personal data is kept in personnel files or within A J Events Services’s Systems. The following types of data may be held by A J Events Services, as appropriate, on relevant individuals:
Contact Details, (Email, Telephone Number)
Type of Services Required.
Relevant individuals should refer to A J Events Services’s privacy notice for more information on the reasons for its processing activities, the lawful bases it relies on for the processing and data retention periods.
Data Protection Principles
All personal data obtained and held by A J Events Services will:
be processed fairly, lawfully and in a transparent manner
be collected for specific, explicit, and legitimate purposes
be adequate, relevant and limited to what is necessary for the purposes of processing
be kept accurate and up to date. Every reasonable effort will be made to ensure that inaccurate data is rectified or erased without delay
not be kept for longer than is necessary for its given purpose
be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures comply with the relevant GDPR procedures for international transferring of personal data.
In addition, personal data will be processed in recognition of an individuals’ data protection rights, as follows:
the right to be informed
the right of access
the right for any inaccuracies to be corrected (rectification)
the right to have information deleted (erasure)
the right to restrict the processing of the data
the right to portability
the right to object to the inclusion of any information
the right to regulate any automated decision-making and profiling of personal data.
A J Events Services has taken the following steps to protect the personal data of relevant individuals, which it holds or to which it has access:
it appoints or employs employees with specific responsibilities for:
the processing and controlling of data the comprehensive reviewing and auditing of its data protection systems and procedures overviewing the effectiveness and integrity of all the data that must be protected.
There are clear lines of responsibility and accountability for these different roles.
it provides information to its employees on their data protection rights, how it uses their personal data, and how it protects it. The information includes the actions relevant individuals can take if they think that their data has been compromised in any way it provides its employees with information and training to make them aware of the importance of protecting personal data, to teach them how to do this, and to understand how to treat information confidentially
it can account for all personal data it holds, where it comes from, who it is shared with and also who it might be shared with it carries out risk assessments as part of its reviewing activities to identify any vulnerabilities in its personal data handling and processing, and to take measures to reduce the risks of mishandling and potential breaches of data security. The procedure includes an assessment of the impact of both use and potential misuse of personal data in and by A J Events Services. It recognises the importance of seeking individuals’ consent for obtaining, recording, using, sharing, storing and retaining their personal data, and regularly reviews its procedures for doing so, including the audit trails that are needed and are followed for all consent decisions. A J Events Servicesunderstands that consent must be freely given, specific, informed and unambiguous. A J Events Services will seek consent on a specific and individual basis where appropriate. Full information will be given regarding the activities about which consent is sought. Relevant individuals have the absolute and unimpeded right to withdraw that consent at any time
It has the appropriate mechanisms for detecting, reporting and investigating suspected or actual personal data breaches, including security breaches. It is aware of its duty to report significant breaches that cause significant harm to the affected individuals to the Information Commissioner, and is aware of the possible consequences
it is aware of the implications international transfer of personal data internationally.
Access to data
Relevant individuals have a right to be informed whether A J Events Services processes personal data relating to them and to access the data that A J Events Servicesholds about them. Requests for access to this data will be dealt with under the following summary guidelines:
A form on which to make a subject access request is available A J Events Services email. The request should be made to A J Events Services email address.
A J Events Services will not charge for the supply of data unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request
A J Events Services will respond to a request without delay. Access to data will be provided, subject to legally permitted exemptions, within one month as a maximum. This may be extended by a further two months where requests are complex or numerous.
Relevant individuals must inform A J Events Services immediately if they believe that the data is inaccurate, either as a result of a subject access request or otherwise. A J Events Services will take immediate steps to rectify the information.
A J Events Services may be required to disclose certain data/information to any person with reasonable request and permissions. These kinds of disclosures will only be made when strictly necessary for the purpose.
A J Events Services adopts procedures designed to maintain the security of data when it is stored and transported.
Personal data relating to employees should not be kept or transported on laptops, USB sticks, or similar devices, unless authorised by the Senior Management Team. Where personal data is recorded on any such device it should be protected by:
ensuring that data is recorded on such devices only where absolutely necessary
using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted
ensuring that laptops or USB drives are not left lying around where they can be stolen.
Failure to follow A J Events Services’s rules on data security may be dealt with via A J Events Services’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.
International Data Transfers
A J Events Services may be required to transfer personal data to a country/countries outside of the EEA. This is because A J Events Services occasionally services clients outside of the EEA. Where this occurs, the following safeguards are adopted appropriate corporate rules/standard data protection rules will be adhered to.
Where a data breach is likely to result in a risk to the rights and freedoms of individuals, it will be reported to the Information Commissioner within 72 hours of A J Events Services becoming aware of it and may be reported in more than one instalment.
Individuals will be informed directly in the event that the breach is likely to result in a high risk to the rights and freedoms of that individual.
If the breach is sufficient to warrant notification to the public, A J Events Services will do so without undue delay.
New employees must read and understand the policies on data protection as part of their induction.
All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.
The nominated data controller/auditors/protection officers for A J Events Services are trained appropriately in their roles under the GDPR.
All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and A J Events Servicesof any potential lapses and breaches of A J Events Services’s policies and procedures.
A J Events Serviceskeeps records of its processing activities including the purpose for the processing and retention periods. These records will be kept up to date so that they reflect current processing activities.
Data Protection Officer
A J Events Services’s Data Protection Officer and can be contacted on firstname.lastname@example.org.