Privacy Policy

EXELBY SERVICES LIMITED

PRIVACY  POLICY

 

Exelby Services Limited is registered under the Data Protection Act.

General Statement of the Company’s Duties and Scope

Exelby Services Limited is required to process relevant personal data regarding members of staff, customers and suppliers as part of its operation and shall take all reasonable steps to do so in accordance with this Policy.

Data Protection Controller

Exelby Services limited has appointed Antonie Hoyle as the Data Protection Controller (DPC) who will endeavour to ensure that all personal data is processed in compliance with this Policy and the Principles of the Data Protection Act 1998. The Freedom of Information Act 2000 and the Protection of Freedoms Act 2012 are also relevant to parts of this policy.

Exelby Services Limited recognises The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) application date of 25 May 2018 and is fully compliant with the directive. Exelby Services Limited will ensure that decision makers and key people in our organisation are aware of GDPR.

The Principles

Exelby Services Limited shall so far as is reasonably practicable comply with the Data Protection Principles (the Principles) contained in the Data Protection Act to ensure all data is:

  • Fairly and lawfully processed
  • Processed for a lawful purpose
  • Adequate, relevant and not excessive
  • Accurate and up to date
  • Not kept for longer than necessary
  • Processed in accordance with the data subject’s rights
  • Secure
  • Not transferred to other countries without adequate protection

Individuals’ Rights

Exelby Services Limited will have procedures in place to ensure an individual’s rights under GDPR are complied with.

The GDPR includes the following rights for individuals:

  • The right to be informed;
  • The right of access;
  • The right to rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to data portability;
  • The right to object; and
  • The right not to be subject to automated decision-making including profiling.

Personal Data

Personal data covers both facts and opinions about an individual where that data identifies an individual. For example, it includes information necessary for employment such as the member of staff’s name and address and details for payment of wages/salary or attendance record. Personal data may also include sensitive personal data as defined in the Act.

Processing of Personal Data

Consent may be required for the processing of personal data unless processing is necessary for the performance of the contract of employment. Any information which falls under the definition of personal data and is not otherwise exempt, will remain confidential and will only be disclosed to third parties with appropriate consent.

Exelby Services Limited processes some customer’s personal data for direct marketing. Data subjects have the right to request an opt-out to these activities.

Sensitive Personal Data

Exelby Services Limited may, from time to time, be required to process sensitive personal data. Sensitive personal data includes data relating to medical information, gender, religion, race, sexual orientation, trade union membership and criminal records and proceedings.

Rights of Access to Information

Data subjects have the right of access to information held by Exelby Services Limited, subject to the provisions of the Data Protection Act 1998 and the Freedom of Information Act 2000. Any data subject wishing to access their personal data should put their request in writing to the DPC. Exelby Services Limited will endeavour to respond to any such written requests as soon as is reasonably practicable and, in any event, within 40 days for access to records and 21 days to provide a reply to an access to information request. The information will be imparted to the data subject as soon as is reasonably possible after it has come to Exelby Services Limited’s attention and in compliance with the relevant Acts.

Exemptions

Certain data is exempted from the provisions of the Data Protection Act which includes the following:

  • National security and the prevention or detection of crime
  • The assessment of any tax or duty
  • Where the processing is necessary to exercise a right or obligation conferred or imposed by law upon Exelby Services Limited, including Safeguarding and prevention of terrorism and radicalisation

The above are examples only of some of the exemptions under the Act. Any further information on exemptions should be sought from the DPC.

Accuracy

Exelby Services Limited will endeavour to ensure that all personal data held in relation to all data subjects is accurate. Data subjects must notify the data processor of any changes to information held about them. Data subjects have the right in some circumstances to request that inaccurate information about them is erased. This does not apply in all cases, for example, where records of mistakes or corrections are kept, or records which must be kept in the interests of all parties to which they apply.

Enforcement

If an individual believes that Exelby Services Limited has not complied with this Policy or acted otherwise than in accordance with the Data Protection Act, the member of staff should utilise Exelby Services Limited grievance procedure (see the Company’s Employee Handbook) and should also notify the DPC.

Data Security

Exelby Services Limited will take appropriate technical and organisational steps to ensure the security of personal data.

All staff will be made aware of this policy and their duties under the Act.

Exelby Services Limited and therefore all staff are required to respect the personal data and privacy of others and must ensure that appropriate protection and security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to all personal data.

An appropriate level of data security must be deployed for the type of data and the data

processing being performed. In most cases, personal data must be stored in appropriate systems and be encrypted when transported offsite. Other personal data may be for publication or limited publication within Exelby Services Limited, therefore having a lower requirement for data security.

External Processors

Exelby Services Limited will ensure that data processed by external processors, for example, service providers, Cloud services including storage, web sites etc. are compliant with this policy and the relevant legislation.

Secure Destruction

When data held in accordance with this policy is destroyed, it will be destroyed securely in accordance with best practice at the time of destruction.

Retention of Data

Exelby Services Limited may retain data for differing periods of time for different purposes as required by statute or best practices, individual departments incorporate these retention times into the processes and manuals. Other statutory obligations, legal processes and enquiries may also necessitate the retention of certain data.

Exelby Services Limited may store some data such as photographs in its archive.

CCTV

Exelby Services Limited owns and operates a CCTV network for the purposes of crime prevention and detection, and Safeguarding.

Automated Number Plate Recognition (ANPR) cameras are in operation to assist in the prevention of crime. Where a data subject can be identified, images will be processed as personal data.

 

Robert Exelby

Director

 

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