Data protection policy
Context and overview
- Approved by board / management on: 24/05/2018.
- Policy became operational on: 24/05/2018.
- Next review date: 23/05/2020.
Nitro Digital needs to gather and use certain information about individuals.
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 Nitro Digital:
Data protection law
- 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 risks of a data breach
The Data Protection Act 1998 describes how organisations – including Nitro Digital –
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:
People, risks and responsibilitiesPolicy scope
- 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
This policy applies to:
- The head office of Nitro Digital
- All branches of Nitro Digital
- All staff and volunteers of Nitro Digital
- All contractors, suppliers and other people working on behalf of Nitro Digital
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
Data protection risks
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- … plus any other information relating to individuals
This policy helps to protect Nitro Digital from some very real data security risks,
- Breaches of confidentiality. For instance, information being given out
- 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 Nitro Digital 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:
General staff guidelines
- The board of directors is ultimately responsible for ensuring that Nitro Digital
meets its legal obligations.
- The Privacy Officer is responsible for:
- Keeping the board updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed
schedule. 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 Nitro Digital 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 manager is responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security
- Performing regular checks and scans to ensure security hardware and software is functioning
- Evaluating any third-party services the company is considering using to store or process
data. For instance, cloud computing services.
- The marketing manager is responsible for:
- Approving any data protection statements attached to communications such as emails and
- Addressing any data protection queries from journalists or media outlets like newspapers.
- Where necessary, working with other staff to ensure marketing initiatives abide by data
- The only people able to access data covered by this policy should be those who need it for
- Data should not be shared informally. When access to confidential information is
required, employees can request it from their line managers.
- Nitro Digital 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
- 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.
- Employees should request help from their line manager or the data protection
officer 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 safely can be directed to the IT manager or 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
- When not required, the paper or files should be kept in a locked drawer or filing
- 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 (like a CD, DVD or USB), 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 services.
- Servers containing personal data should be sited in a secure location, away from general office
- 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
or 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 Nitro Digital 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.
- 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 Nitro Digital 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 Nitro Digital 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.
Subject access requests
- 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.
- Nitro Digital will make it easy for data subjects to update the information Nitro
Digital holds about them. For instance, via the 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 manager’s responsibility to ensure marketing databases are checked against
industry suppression files every six months.
All individuals who are the subject of personal data held by Nitro Digital are
- 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 the company requesting this information, this is
called a subject access request. Subject access requests from individuals should be made by email,
addressed to the data controller at [email address]. The data controller 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 controller will aim to provide the relevant data within 14 days. The data controller
will always verify the identity of anyone making a subject access request before handing over any
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, Nitro Digital will disclose requested data. However, the data controller will ensure the
request is legitimate, seeking assistance from the board and from the company’s legal advisers where
Nitro Digital aims to ensure that individuals are aware that their data is being
processed, and that they understand:
- How the data is being used
- How to exercise their rights