HPL Prototypes Ltd will use personal and special category information about employees with whom it holds contractual obligations for the sole purpose of it’s business requirements. This information will be dealt with properly and securely however it is collected, recorded and used – whether on paper, in a computer, or recorded on other material – and there are safeguards to ensure this within the Data Protection Act 1998.

HPL Prototypes Ltd regards the lawful and correct treatment of personal information as very important to the successful and efficient performance of its functions, and to maintain confidence between those with whom it deals.

To this end HPL Prototypes Ltd fully endorses and adheres to the Principles of Data Protection, as set out in the Data Protection Act 1998.

Purpose

The purpose of this policy is to ensure that the staff and contractors of HPL Prototypes Ltd are clear about the purpose and principles of Data Protection and to ensure that it has guidelines and procedures in place which are consistently followed.

Failure to adhere to the Data Protection Act 1998 is unlawful and could result in legal action being taken against HPL Prototypes Ltd, its staff or contractors.

Principles

The Data Protection Act 1998 regulates the processing of information relating to living and identifiable individuals (data subjects). This includes the obtaining, holding, using or disclosing of such information, and covers computerised records as well as manual filing systems.

Data users must comply with the data protection principles of good practice which underpin the Act. To comply with the law, information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully.

To do this HPL Prototypes Ltd follows the eight Data Protection Principles outlined in the Data Protection Act 1998, which are summarised below:

1. Personal data will be processed fairly and lawfully
2. Data will only be collected and used for specified purposes
3. Data will be adequate, relevant and not excessive
4. Data will be accurate and up to date
5. Data will not be held any longer than necessary
6. Data subject’s rights will be respected
7. Data will be kept safe from unauthorised access, accidental loss or damage
8. Data will not be transferred to a country outside the European Economic Area, unless that country has equivalent levels of protection for personal data.

The principles apply to “personal data” which is information held on computer or in manual filing systems from which they are identifiable. HPL Prototypes Ltd’s employees and contractors who process or use any personal information in the course of their duties will ensure that these principles are followed at all times.

Procedures

The following procedures have been developed in order to ensure that HPL Prototypes Ltd meets its responsibilities in terms of Data Protection. For the purposes of these procedures data collected, stored and used by HPL Prototypes Ltd falls into 2 broad categories:

1. HPL Prototypes Ltd’s internal data records; Staff and Contractors.

2. HPL Prototypes Ltd’s external data records; Customers, Clients & third parties.

HPL Prototypes Ltd as a body is a DATA CONTROLLER under the Act, and the Directors are ultimately responsible for the policy’s implementation.

Internal data records

Purposes

HPL Prototypes Ltd obtains personal data (names, addresses, phone numbers, email addresses), application forms, and references and in some cases other documents from staff and contractors. This data is stored and processed for the following purposes:

• Equal Opportunities monitoring and Performance related topics
• To distribute relevant organisational material
• Payroll

Access

The contact details of staff and contractors will only be made available to other internal staff and contractors. Any other information supplied on application or requested throughout the terms of contract will be kept in a secure filing cabinet and is not accessed after the day to day running of the company.

Contact details of staff contractors will not be passed on to anyone outside the company without their explicit consent.

A copy of staff and contractor emergency contact details will be kept in the Emergency File for Health and Safety purposes to be used in emergency situations e.g. accidents, fire/ bomb evacuations, etc..

Staff and contractors will be supplied with a copy of their personal data held by the company if a request is made.

All confidential post must be opened by the addressee only.

Accuracy

HPL Prototypes Ltd will take reasonable steps to keep personal data up to date and accurate. Personal payroll data will be stored for 7 years after an employee or contractor has worked for the company.

External data records

Purposes

HPL Prototypes Ltd obtains personal data (such as names, addresses, and phone numbers) from clients, customers and third parties. This data is obtained, stored and processed solely to assist staff in the efficient running of services. Personal details supplied are only used to send material that is potentially useful. Most of this information is stored on the company’s database. This data is stored and processed only for the purposes outlined in the agreement.

Consent

Personal data is collected using methods such as e-mail, hard copy mail received and photocopying. During this initial contact, the data owner is provided with an explanation of how this information will be used. Written consent is not requested as it is assumed that the consent has been granted when an individual freely gives their own details.

Personal data will not be passed on intentionally to anyone outside the company without explicit consent from the data owner unless there is a legal duty of disclosure under other legislation, in which case the Managing Director will discuss and agree disclosure with the Directing body.

Access

Only the company’s staff will normally have access to personal data. All staff and contractors are made aware of the Data Protection Policy and their obligation not to disclose personal data to anyone who is not supposed to have it.

Information supplied is kept in a secure filing, paper and electronic system and is only accessed by those individuals involved in the delivery of the service.

Information will not be passed on to anyone outside the company without their explicit consent, excluding statutory bodies e.g. the Inland Revenue.

Individuals will be supplied with a copy of any of their personal data held by the company if a request is made.

All confidential post must be opened by the addressee only.

Accuracy

HPL Prototypes Ltd will take reasonable steps to keep personal data up to date and accurate. Personal data will be stored for as long as the data owner uses our services and normally longer. Where an individual cease to use our services and it is not deemed appropriate to keep their records, their records will be destroyed. However, unless we are specifically asked by an individual to destroy their details, we will normally keep them on file for future reference.

If a request is received from a company/individual to destroy their records, we will remove their details from the database and request that all staff holding paper or electronic details for the company destroy them. This work will be supervised by the Directors of the company. This procedure applies if HPL Prototype Ltd is informed that a company ceases to exist.

General Policy

Storage

Personal data may be kept in paper-based systems and on a password-protected computer system. Paper-based data are stored in organised and secure systems.

HPL Prototypes Ltd operates a clear desk policy at all times.

Use of Photographs

Where practicable, HPL Prototypes Ltd will seek consent of individuals before displaying photographs in which they appear. If this is not possible (for example, a large group photo), the company will remove any photograph if a complaint is received. This policy also applies to photographs published on the company’s website or in the Newsletter.

Criminal Records Bureau

HPL Prototypes Ltd will act in accordance with the CRB’s code of practice.

Copies of disclosures are kept for no longer than is required. In most cases this is no longer than 6 months in accordance with the CRB Code of Practice. There may be circumstance where it is deemed appropriate to exceed this limit e.g. in the case of disputes.

Responsibilities of staff, volunteers and trustees

During the course of their duties with HPL Prototypes Ltd’s staff and contractors will be dealing with information such as names/addresses/phone numbers/e-mail addresses of staff. They may be told or overhear sensitive information while working for HPL Prototypes Ltd. The Data Protection Act (1988) gives specific guidance on how this information should be dealt with. In short, to comply with the law, personal information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully. Staff, paid or unpaid must abide by this policy.

Compliance

Compliance with the Act is the responsibility of all staff, paid or unpaid. HPL Prototypes Ltd will regard any unlawful breach of any provision of the Act by any staff, paid or unpaid, as a serious matter which will result in disciplinary action. Any employee who breaches this policy statement will be dealt with under the disciplinary procedure which may result in dismissal for gross misconduct. Any such breach could also lead to criminal prosecution.

Any questions or concerns about the interpretation or operation of this policy statement should in the first instance be referred to the line manager.

Retention of Data

No documents will be stored for longer than is necessary.

All documents containing personal data will be disposed of securely in accordance with the Data Protection principles.