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Data Protection Policy

Context and Overview
CreativeOpolis needs to gather and use certain information about individuals and organisations.

These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the Company’s data protection standards, and to comply with the law.

Why This Policy Exists
This Data Protection Policy ensures CreativeOpolis:
• Complies with data protection law and follows good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals’ and organisations’ data
• Protects itself from the risks of a data breach

Data Protection Law
The Data Protection Act 1998 describes how organisations, including CreativeOpolis, must collect, handle and store personal information.

These rules apply regardless of 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:
1. Be processed fairly and lawfully
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. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

People, Risks and Responsibilities

Policy Scope
This policy applies to:
• The head office of CreativeOpolis
• Any and all branches of CreativeOpolis
• All staff and volunteers of CreativeOpolis
• All contractors, suppliers and other people working on behalf of CreativeOpolis

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 1998. This can include:
• Names of individuals and organisations
• Postal addresses
• Email addresses
• Telephone numbers
• Plus any other information relating to individuals and organisations

Data Protection Risks
This policy helps to protect CreativeOpolis from some very real data security risks, including:
• Breaches of confidentiality. For instance, information being given out inappropriately
• Failing to offer choice. For instance, all individuals and organisations should be free to choose how CreativeOpolis uses data relating to them
• Reputational damage. For instance, CreativeOpolis could suffer if hackers successfully gained access to sensitive data

Responsibilities
Everyone who works for or with CreativeOpolis has some responsibility for ensuring data is collected, stored and handled appropriately.

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 / owners is / are ultimately responsible for ensuring that CreativeOpolis meets its legal obligations
• CreativeOpolis is responsible for:
o Keeping the board / owners updated about data protection responsibilities, risks and issues
o Reviewing all data protection procedures and related policies, in line with an agreed schedule
o Arranging data protection training and advice for the people covered by this policy
o Handling data protection questions from staff and anyone else covered by this policy
o Dealing with requests from individuals and / or organisations to see the data CreativeOpolis holds about them (also called ‘subject access requests’)
o Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data
• CreativeOpolis is responsible for:
o Ensuring all systems, services and equipment used for storing data meet acceptable security standards
o Performing regular checks and scans to ensure security hardware and software is functioning properly
o Evaluating any third-party services that CreativeOpolis is considering using to store or process data. For instance, cloud computing services
• CreativeOpolis is responsible for:
o Approving any data protection statements attached to communications such as emails and letters
o Addressing any data protection queries from journalists or media outlets i.e. newspapers
o Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles

General Staff Guidelines
• The only people able to access data 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
• CreativeOpolis 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 and disposed of securely
• 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 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 cabinet
• Employees should make sure paper and printouts are not left where unauthorised people could see them i.e. 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 (i.e. CD or DVD), these should be kept locked away securely when not being used
• Data should only be stored on designated drives and servers, and should only be uploaded to anapproved 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 i.e. tablets or smart phones
• All servers and computers containing data should be protected by approved security software and a firewall

Data Use
Personal data is of no value to CreativeOpolis 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
• Currently, 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 CreativeOpolis 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 CreativeOpolis 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 make contact
• CreativeOpolis will make it easy for data subjects to update the information CreativeOpolis holds about them. For instance, via the CreativeOpolis company website
• Data should be updated as and when 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 responsibility of CreativeOpolis to ensure marketing databases are checked against industry suppression files every six months

Subject Access Requests
All individuals and organisations who are the subject of personal data held by CreativeOpolis 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 or organisation contacts the Company requesting this information, this is called a subject access request.

Subject access requests from individuals and organisations should be made by opening a ticket in the CreativeOpolis Support area. The Company can supply a standard request form, although individuals and organisations do not have to use this.

Individuals will be charged £30 per subject access request. CreativeOpolis will aim to provide the relevant data within 14 days.

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

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, CreativeOpolis will disclose requested data. However, the Company will ensure the request is legitimate, seeking assistance from managerial staff and, where necessary, from the Company’s legal advisers.

GDPR
You can at anytime, under the GDPR 2018 legislation, opt-out of any future correspondence or contact from CreativeOpolis, which will involve having your data removed from our records. Please contact us if you wish to proceed.

• You can learn more about GDPR here: eugdpr.org

• Here is an FAQ page: eugdpr.org/gdpr-faqs

Providing Information
CreativeOpolis aims to ensure that individuals and organisations 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, CreativeOpolis has a Privacy Policy, setting out how data relating to individuals and organisations is used by the Company.