Reconnect Weekends is an entity of Coaching for Talent and iPapilio JS Ltd. Coaching for Talent and iPapilio JS Ltd need to gather and use certain information about individuals in order to ensure high quality service for all partners.
These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
Our data 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 data policy exists
The data protection policy ensures Coaching for Talent and iPapilio JS Ltd:
- Complies with data protection law and follow good practice
- Protects the rights of staff, customers and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risk of a data breach
Data protection law
The Data Protection Act 1998 describes how organisations – including Coaching for Talent and iPapilio JS Ltd – must collect, handle and store personal informtion.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the new 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:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- 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
This data policy applies to:
- The head office of Coaching for Talent, and iPapilio JS Ltd
- All branches of Coaching for Talent and iPapilio JS Ltd (of which there’s only currently one of each)
- All staff and volunteers of Coaching for Talent and iPapilio JS Ltd
- All contractors, suppliers and other people working on behalf of Coaching for Talent and iPapilio JS Ltd
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
- Postal addresses
- Email addresses
- Telephone numbers
- Interests of the individual where relevant and necessary
- Occupation where relevant and necessary
Data protection risks
This policy helps to protect Coaching for Talent and iPapilio JS Ltd 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 should be free to choose how the company uses data relating to them.
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with Coaching for Talent and iPapilio JS Ltd 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 directors are ultimately responsible for ensuring that Coaching for Talent and iPapilio JS Ltd meet their legal obligations.
- The Data Protection Officers, Joanna Davis and Emma Davis, are responsible for:
- Keeping directors updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data Coaching for Talent and/or iPapilio JS Ltd holds about them (also called ‘subject access requests’).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
- The IT Managers, Joanna Davis and Emma Davis, are responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software is functioning properly.
- Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
- The Marketing Managers, Joanna Davis and Emma Davis, are responsible for:
- Approving any data protection statements attached to communications such as emails and letters.
- Addressing any data protections queries from journalists or media outlets like newspapers.
- 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 manager.
- Coaching for Talent and iPapilio JS Ltd 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 not longer required, it should be deleted and disposed of.
- Employees should request help from their manager or the data protections offices if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data can be directed to the IT Managers or Data Protection Officers.
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, like 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 (lie a 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 an approved cloud computing service.
- 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 like tablets of smart phones.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Coaching for Talent and iPapilio JS Ltd unless the businesses 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 managers can explain how to send data to authorised external contacts.
- 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.
The law requires Coaching for Talent and iPapilio JS Ltd 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 Coaching for Talent and iPapilio JS Ltd 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 call.
- Coaching for Talent, iPapilio JS Ltd and Reconnect Weekends will make it easy for data subjects to update information Coaching for Talent and/or iPapilio JS Ltd holds about them. For instance, via company website.
- Data should be updated as 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 marketing managers’ responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject access requests
All individuals who are the subject of personal data held by Coaching for Talent and/or iPapilio JS Ltd 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 contacts one or both companies requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to one of the data controllers (Joanna Davis – firstname.lastname@example.org, Emma Davis – email@example.com). The data controllers can supply a standard request form, although individuals do not have to use this.
Individuals will be charged £10 per subject access request. The data controllers will aim to provide the relevant data within 14 days.
The data controllers 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, Coaching for Talent and iPapilio JS Ltd will disclose requested data. However, the data controllers will ensure the request is legitimate, seeking assistance from legal advisors where necessary.
How we use data and how to exercise rights
Where users and customers have opted in, Coaching for Talent and iPapilio JS Ltd collect different types of information about customers and users for the following main reasons:
- To provide personalised services unique to individual users/customers
- To help us monitor and improve services we offer
- If we have permission from the user/customer, to market services to them
- To send service-related notices (including any notices required by law).
With this in mind, if you don’t want to receive these messages, you can opt out by following the instructions in the message, or you can email Joanna Davis at firstname.lastname@example.org or Emma Davis at email@example.com. If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.
At Reconnect Weekends we are committed to protecting your personal information and respecting your privacy. When it comes to cookies, we follow the same principles.
We have done our best to keep this policy as simple as possible. If you have any questions regarding this policy, please email firstname.lastname@example.org.
What are cookies?
Cookies are small pieces of text placed on your computer, tablet or mobile phone by websites you visit. They are widely used to make websites better, more efficient and more personal.
Reconnect Weekends (iPapilio JS Ltd and/or Coaching for Talent) actively use a very limited number of cookies. The details of the cookies used can be found below:
These cookies collect aggregate statistical data to help us improve our website presentation and the usability of our navigation.
We receive information such as the number of visitors we have to our site, where they come from and which pages they visit. As Google only provides aggregated data, the information we have is anonymous.
These cookies collect aggregate statistical data to help us improve our communication with you to ensure you are being presented with the most up to date and relevant information to assist you in your search.
What are your choices regarding cookies
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
Notice Prepared by: Joanna Davis
Approved by directors on: 08/05/2018
Policy became operational on: 08/05/2018
Next review date: 08/05/2019