CCR3 One Source

Data Protection Policy, including GDPR & Key Procedures

Aims of this Policy

CCR3 Limited needs to keep certain information on its clients and associate partners clients to carry out its day to day operations, to meet its objectives and to comply with legal obligations.

The organisation is committed to ensuring any personal data will be dealt with in line with the Data Protection Act 1998. In addition, CCR3 has taken the steps outlined by the IDC to comply with GDPR as there are some differences which may apply to our operations. To comply with the law, personal information will be collected and used fairly, stored safely and not disclosed to any other person unlawfully.

The aim of this policy is to ensure that everyone handling personal data is fully aware of the requirements and acts in accordance with data protection procedures. This document also highlights key data protection procedures within the organisation.

This policy covers all parties associated contractually with CCR3

According to IDC, the European Union (EU) General Data Protection Regulation (GDPR) is the most significant privacy regulation update since 1995. GDPR was passed in April 2016 and took effect on 25 May 2018.

Every organisation, including CCR3 Limited, that collects and/or processes data of people in the EU is subject to GDPR and needs to comply. There are five processes required to comply.

This outlines what CCR3 has done in advance to be compliant in GDPR and how using a data management platform enables us to comply.

Definitions

In line with the Data Protection Act 1998 principles, as well as the current GDPR guidelines, CCR3 Limited will ensure that personal data will:

The definition of ‘Processing’ is obtaining, using, holding, amending, disclosing, destroying and deleting personal data. This includes some paper based personal data as well as that kept on computer.

The Personal Data Guardianship Code suggests five key principles of good data governance on which best practice is based. CCR3 Limited will seek to abide by this code in relation to all the personal data it processes, i.e.

Type of information processed

CCR3 Limited processes the following personal information:

Personal information is encrypted and kept in/on the following forms:

Groups of people within the organisation who will process personal information are:

Notification

If necessary, due to the needs of a specific client/body that requires publication of the data, any such need for processing personal data would be recorded on the public register maintained by the Information Commissioner. We would notify and/or renew our notification on an annual basis as the law requires.

If there are any interim changes, these will be notified to the Information Commissioner within 28 days.

The name of the Data Controller within our organisation as specified in our notification to the Information Commissioner is Lorraine Hucker.

Responsibilities

Under the Data Protection Guardianship Code, overall responsibility for personal data in our organisation rests with the Cross Functional Data Governance Team (DGT). In the case of CCR3 Limited, this is members of the Senior Management Team.

The DGT delegates tasks to the Data Controller. The Data Controller is responsible for:

All CCR3 Staff and associates who process personal information under this section are trained to ensure they not only understand but also act in line with this policy and the data protection principles.

Any breach of this policy will result in the appropriate action being taken to protect the client’s data and the integrity of CCR3 Limited.

Policy Implementation

To meet our responsibilities, CCR3 Limited will:

CCR3 Limited will ensure that:

Queries about handling personal information will be dealt with swiftly and politely.

Training

Relevant training and raising awareness about the Data Protection Act/GDPR and how it is followed in this organisation will take the following forms:

In addition, general reminders, specific changes in procedures and in law are communicated throughout the company.

Gathering and checking information

Before personal information is collected, we will consider the needs of the contract and the outcomes required from our computer systems and consultative methodologies.

We will inform people whose information is gathered about the following:

We will take the following measures to ensure that personal information kept is accurate:

Data Security

CCR3 Limited will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure. The following measures will be taken:

Any unauthorised disclosure of personal data to a third party by an employee will result in legal action and immediate dismissal.

Subject Access Requests

Anyone whose personal information we process has the right to know:

They also have the right to prevent processing of their personal data in some circumstances and the right to correct, rectify, block or erase information regarded as wrong.

Individuals have a right under the Act to access certain personal data being kept about them on computer and other files. Any person wishing to exercise this right should apply in writing to;

CCR3 Limited
Legal Department
Innovation Centre
1 Ainslie Road
Hillington Park
Glasgow G52 4RU

We may make a charge for information on each occasion where access is requested and granted.

The following information will be required before access is granted:

Where we require proof of identity before access is granted, the following forms of ID will be required:

Queries about handling personal information will be dealt with swiftly and politely. We will aim to comply with requests for access to personal information as soon as possible, but will ensure it is provided within the 28 days required by the Act from receiving the written request, free of charge.

Review

This policy will be reviewed at intervals of 12 months to ensure it remains up to date and compliant with the law.