Introduction
Illumini Technology Limited is required to maintain certain personal data about individuals for the purposes of satisfying operational and legal obligations. The Company recognises the importance of the correct and lawful treatment of personal data; it maintains confidence in the organisation and provides for successful operations. This personal data, whether it is held on paper, on computer or other media, will be subject to the appropriate legal safeguards as specified in the Data Protection Act 1998.
Illumini Technology Limited fully endorses and adheres to the eight principles of the Data Protection Act. These principles specify the legal conditions that must be satisfied in relation to obtaining, handling, processing, transporting and storing personal data. Employees and any others who obtain, handle, process, transport and store personal data for Illumini Technology Limited must adhere to these principles.
Scope
All employees, contractors and temporary workers who obtain, handle, process, transport and store personal data for Illumini Technology Limited.
Principles
The principles require that personal data shall:
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Be processed fairly and lawfully and shall not be processed unless certain conditions are met;
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Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose;
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Be adequate, relevant and not excessive for those purposes;
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Be accurate and, where necessary, kept up to date;
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Not be kept for longer than is necessary for that purpose;
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Be processed in accordance with the data subject’s rights;
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Be kept secure from unauthorised or unlawful processing and protected against accidental loss, destruction or damage by using the appropriate technical and organisational measures;
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And not be transferred to a country or territory outside the European Economic Area, unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
Satisfaction of principles
In order to meet the requirements of the principles, Illumini Technology Limited will:
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Observe fully the conditions regarding the fair collection and use of personal data;
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Meet its obligations to specify the purposes for which personal data is used;
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Collect and process appropriate personal data only to the extent that it is needed to fulfil operational or any legal requirements;
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Ensure the quality of personal data used;
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Apply strict checks to determine the length of time personal data is held;
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Ensure that the rights of individuals about whom the personal data is held, can be fully exercised under the Act;
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Take the appropriate technical and organisational security measures to safeguard personal data;
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Ensure that personal data is not transferred abroad without suitable safeguards.
Designated Data Controller
The Data Protection Officer is responsible for ensuring compliance with the Data Protection Act and implementation of this policy on behalf of the Directors and the Company. Any questions or concerns about the interpretation or operation of this policy should be taken up with them in the first instance.
Any employee who considers that the policy has not been followed in respect of personal data about themselves should raise the matter with their Line Manager.
Subject access
All individuals who are the subject of personal data held by the Company are entitled to:
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Ask what information the Company holds about them and why.
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Ask how to gain access to it.
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Be informed how to keep it up to date.
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Be informed what the Company is doing to comply with its obligations under the Data Protection Act.
Employee responsibilities
All employees are responsible for:
• Checking that any personal data they provide to the Company is accurate and up to date.
• Informing the Company of any changes to information they have provided e.g. changes of address.
• If, as part of their responsibilities, employees collect information about other people e.g. bank details, they must comply with this policy and the Data Protection Act principles.
Data security
The need to ensure that data is kept securely means that precautions must be taken against physical loss or damage, and that both access and disclosure must be restricted. All employees are responsible for ensuring that:
• Any personal data which they hold is kept securely.
• Personal information is not disclosed either orally or in writing or otherwise to any unauthorised third party.
Rights to access information
Employees and other subjects of personal data held by Illumini Technology Limited have the right to access any personal data that is being kept about them on computer and also have access to paper-based data held in certain manual filing systems. This right is subject to certain exemptions which are set out in the Data Protection Act. Any employee who wishes to exercise this right should make the request in writing to the HR team. For any other individual, they should make their request in writing to the Directors. The Company reserves the right to charge the maximum fee payable for each subject access request. If personal details are inaccurate, they can be amended upon request.
The Company aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 40 days of the request being received by the Company, unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual making the request.
In the event of a disagreement between an employee and the Company regarding personal data, the matter should be taken up under the Company’s formal Grievance Procedure.
Retention of data
The Company will keep some information, however all employees are responsible for ensuring that information is not kept for longer than necessary.