Conveyorsystemsltd.co.uk collects certain information or data about you when you complete the contact us form or the newsletter sign up form.
• Name, position, email address, telephone number, company, referral information and the enquiry. Subscription preferences are also collected
• Through Google Analytics details of which version of web browser was used, location, referral details etc
• Information on how you use the site, using cookies and page tagging techniques
This data can be viewed by authorised people at CSL and supplier organisations (web designer, PPC supplier and SEO supplier, to:
• Improve the site by monitoring how you use it
• Gather feedback to improve our services, for example our email alerts
• Respond to any feedback you send us, if you’ve asked us to
• Respond to any questions or enquires
Where your data is stored
We store your data on secure servers in the European Economic Area (EEA).
Keeping your data secure
Sending information over the internet is generally not completely secure, and we can’t guarantee the security of your data while it’s in transit.
Any data you send is at your own risk.
We have procedures and security features in place to keep your data secure once we receive it.
Disclosing your information
We may pass on customers details to suppliers and contractors as part of our service offering. Information passed on will be kept minimal.
We won’t share your information with any other organisations for marketing, market research or commercial purposes, and we don’t pass on your details to other websites.
You can find out what information we hold about you and ask us not to use any of the information we collect.
If you’ve signed up for email newsletters, you can unsubscribe by selecting the ‘unsubscribe’ link that appears in every email. Alternatively replying to the newsletter with UNSUBSCRIBE will be immediately actioned.
Links to other websites
Conveyorsystemsltd.co.uk contains links to other websites.
Following a link to another website
For more information
For more information please send your request to firstname.lastname@example.org
Data Protection Policy
Data Protection Policy for Conveyor systems Ltd
Conveyor systems Ltd (CSL) regards the lawful and correct processing of personal and sensitive data as an integral part of its purpose. CSL believes this is vital for maintaining the confidence of customers, employees and other stakeholders about whom we process data, and ourselves.
This Data Protection Policy explains how CSL will meet its legal obligations concerning confidentiality and data security standards. The requirements within the policy are primarily based upon the EU General Data Protection Regulation (EU GDPR), which is the key piece of legislation covering data security and confidentiality of personal and sensitive personal data in the European Union.
- CSL will fully implement all aspects of the EU GDPR.
- CSL will ensure all employees and others handling personal data are aware of their obligations and rights under the EU GDPR.
- CSL will implement adequate and appropriate physical and technical measures and organisational measures to ensure the security of all data contained in or handled by its systems.
The main focus of this policy is to provide guidance about the protection, sharing and disclosure of personal data, but it is important to stress that maintaining confidentiality and adhering to data protection legislation applies to anyone handling personal data or personal sensitive data on behalf of CSL.
Registration with the Information Commissioner
The Digital Economy Act 2017 requires every data controller (i.e. organisation) in the UK to pay a fee to the Information Commissioner’s Office (ICO) and outline the categories of data they hold about people, and what they do with it.
CSL is registered with the ICO to allow us to process personal information to enable us to provide manufacturing services, promote our goods and services, maintain our accounts and records and to support and manage our staff. We also process personal information using a CCTV system to maintain the security of the premises and for preventing and investigating crime.
Definitions of Personal Data and Sensitive Personal Data
- All identifiable customer data
- All identifiable employee data
- All identifiable stakeholder data
Examples of personal identifiable data CSL processes include:
- Names, addresses, emails, phone numbers and other contact information
- National insurance numbers and payroll data
- Photographs, video
- Physical or mental health or condition
- Bank account details, any official identification details such as passport or driving licence numbers etc.
Data Protection Principles
The eight Data Protection principles that lie at the heart of the EU GDPR give the Regulation its strength and purpose. To this end, CSL endorses and abides by the principles of data protection. Specifically, the six principles require that:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or are rectified without delay;
- kept in a form which permits identification of the data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals, and;
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Personal data and sensitive personal data must not be used other than for the specific purpose required to deliver a product or service. The individual should always know that their data is being processed. When that data is especially sensitive, consent is required before the data can be processed by CSL.
A record can be in computerised and/or in a physical format. It may include such documentation as:
- Manually stored paper files e.g. quotations, project files, sales files etc
- Hand written notes
- Letters/E-mails to or from CSL
- Electronic records
Backup data (i.e. archived data or disaster recovery records) also falls under the DPA; however, a search within them should only be conducted if specifically asked for by an individual as an official Subject Access Request.
Rights of Access by Individuals
The EU GDPR gives every living person (or their authorised representative) the right to apply for access to the personal data which organisations hold about them irrespective of when and how they were compiled, i.e. hand written records, electronic and manual records held in a structured file. This is called a Subject Access Request. The EU GDPR treats personal data relating to employees, members and clients alike.
Understanding and complying with the eight Data Protection Principles is the key to understanding and complying with CSL’s responsibilities as the data controller. Therefore, CSL will, through appropriate management, and strict application of criteria and controls:
- Ensure that there are lawful grounds for using the personal data
- Ensure that the use of the data is fair and meets one of the specified conditions
- Only use sensitive personal data where we have obtained the individual’s explicit consent (unless an exemption applies)
- Only use sensitive personal data, if it is absolutely necessary
- Explain to individuals, at the time their personal data is collected, how that information will be used
- Only obtain and use personal data for those purposes which are known to the individual
- Ensure personal data is only used for the purpose it was given. If we need to use the data for other purposes, further consent will be obtained.
- Only keep personal data that is relevant to CSL
- Keep personal data accurate and up to date
- Only keep personal data for as long as is necessary
- Always adhere to our Subject Access Request Procedure and be receptive to any queries, requests or complaints made by individuals in connection with their personal data
- Ensure individuals are given the opportunity to ‘opt in’ to receiving mass communications
- Take appropriate technical and organisational security measures to safeguard personal data.
In addition, CSL will ensure that:
- There is an employee appointed as the Security Information Risk Owner with specific responsibility for Data Protection at CSL. This is currently the Mike Graham.
- Everyone managing and handling personal data and sensitive personal data understands that they are legally responsible for following good data protection practice and has read the Data Protection Policy.
- Everyone managing and handling personal data and sensitive personal data is appropriately supervised by their line manager.
- Enquiries about handling personal data and sensitive personal data are dealt with promptly.
- Methods of handling personal data and sensitive personal data are clearly described in polices and guidance.
- A review and audit of data protection arrangements is undertaken annually. This will take place each year.
- Methods of handling personal data and sensitive personal data are regularly assessed and evaluated by the Security Information Risk Owner and relevant members of the Executive team.
- Performance with personal data and sensitive personal data handling is regularly assessed and evaluated by the Security Information Risk Owner and relevant members of the Executive team.
- Formal written Data Processing Agreements are in place before any personal data and sensitive personal data is transferred to a third party.
Roles and Responsibilities
Maintaining confidentiality and adhering to data protection legislation applies to everyone at CSL. CSL will take necessary steps to ensure that everyone managing and processing personal data understands that they are responsible for following good data protection practice. Employees will receive training and sign the CSL Data Protection Policy as part of their induction.
All employees, volunteers and contractors have a responsibility to:
- Observe all guidance and codes of conduct in relation to obtaining, using and disclosing personal data and sensitive personal data
- Obtain and process personal data and sensitive personal data only for specified purposes
- Only access personal data and sensitive personal data that is specifically required to carry out their activity or work
- Record data correctly in both manual and electronic records
- Ensure any personal data and sensitive personal data is held is kept secure
- Ensure that personal data and sensitive personal data is not disclosed in any form to any unauthorised third party
- Ensure personal data and sensitive personal data is sent securely
- Read and sign the policy, directing any questions to Mike Graham
Failure to adhere to any guidance in this policy could mean an individual(s) being criminally liable for deliberate unlawful disclosure under the EU GDPR. This may result in criminal prosecution and/or disciplinary action.
All Managers are responsible for:
- Determining if their operational area holds personal data and sensitive personal data and ensuring that the data is adequately secure, access is controlled and that the data is only used for the intended purposes
- Providing clear messaging to their teams about data protection requirements and measures
- Ensuring personal and sensitive personal data is only held for the purpose intended
- Ensuring personal and sensitive personal data is not communicated or shared for non-authorised purposes
- Ensuring personal and sensitive personal data is password protected when transmitted or appropriate security measures are taken to protect when in transit or storage.
Security Information Risk Owner – Mike Graham holds the post of Security Information Risk Owner. Responsibilities include:
- Ensuring compliance with legislation principles
- Ensuring notification of processing of personal data and sensitive personal data to the ICO is up to date
- Providing guidance and advice to employees in relation to compliance with legislative requirements
- Auditing data protection arrangements annually
- Reporting on any breaches of Data Protection legislation
- Ensuring those handling personal data are aware of their obligations by producing relevant policies, auditing the arrangements and ensuring the relevant people receive training
In the Security Information Risk Owner’s absence, advice can be gained from https://ico.org.uk/.
Responsibility of Mike Graham– As the Senior Executive, Mike Graham has overall responsibility for Data Protection within CSL. CSL has a duty to ensure that the requirements of the DPA are upheld.
The Information Commissioner’s Office (ICO) – The Information Commissioner’s Office is responsible for overseeing compliance e.g. investigating complaints, issuing codes of practice and guidance, maintaining a register of Data Protection Officers. Any failure to comply with DPA may lead to investigation by the ICO which could result in serious financial or other consequences for CSL.
Breach of Policy
In the event that an employee fails to comply with this policy, the matter may be considered as misconduct and dealt with in accordance with CSL’s Disciplinary Policy.
Any individuals or organisations with whom CSL data has been shared may be personally liable for any breach of the EU GDPR.
Dealing with a Data Breach
If a data breach is suspected, the person who identified the breach should immediately:
- Notify Mike Graham
- Complete and return the Data Incident Reporting Form, which is available from the Security Information Risk Owner.
Following notification of a breach, the Security Information Risk Owner will take the following action as a matter of urgency:
- Implement a recovery plan, which will include damage limitation
- Assess the risks associated with the breach
- Inform the appropriate people and organisations that the breach has occurred
- Review CSL response and update our information security
Glossary of Terms
An individual who is the subject of personal data or sensitive personal data. This includes employees, members, volunteers, clients, residents and tenants.
A person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data and sensitive personal data are, or are to be processed.
The data controller is CSL.
In relation to personal data or sensitive personal data, this refers to any person who processes that data on behalf of the data controller but it is not employed by them.
Data Processors include but are not limited to mailing houses to which CSL sends mailing lists and external companies who have access to CSL’s data.
In relation to personal data or sensitive personal data, this refers to any person other than the data subject, the data controller, or any data processor or other person authorised to process data for data controller or processor. For example, the Police or HMRC.
Recording or holding data or carrying out any operations on that data including organising, altering or adapting it; disclosing the data or aligning, combining, blocking or erasing it.
The person who takes data from a data source, such as a database, which may then be used for further activity. For example, an employee querying the database to print a list of address labels for letters.
A failure leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data or sensitive personal data.
Subject Access Request
A written, signed request (which includes email and other written formats) from an individual to see data which CSL holds about them. The Data Controller