Data Protection Policy
Policy prepared by: Susan Birth. This Policy is operational as from autumn 2018.
The artist Susan Birth needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees/helpers and other people the artist has a relationship with or may need to contact. This policy describes how this personal data must be collected, handled and stored to meet data protection standards, and to comply with the law.
Why this policy exists
This data protection policy ensures that Susan Birth:
∙ Complies with data protection law and follows good practice
∙ Protects the rights of employees/helpers, customers and partners
∙ Is open about how her art business stores and processes individuals’ data
∙ Protects her art business from the risks of a data breach.
Data protection law
The General Data Protection Regulation (GDPR) May 2018 describes how organisations and businesses, including Susan Birth’s art business, must collect, handle and store personal information. These regulations 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 GDPR 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 policy applies to: ∙ The office/workplace/exhibition space of Susan Birth ∙ All/any employees/helpers and volunteers of Susan Birth ∙ All/any contractors, suppliers and other people working directly on behalf of Susan Birth. It applies to all data that her art business may hold relating to identifiable individuals, even if that information technically falls outside of GDPR. This can include: ∙ Names of individuals ∙ Postal addresses ∙ Email addresses ∙ Telephone numbers ∙ Any other information relating to individuals.
Data protection risks
This policy helps to protect Susan Birth 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 Susan Birth uses data relating to them ∙ Reputational damage. For instance, Susan Birth could suffer if hackers successfully gained access to sensitive data.
Susan Birth and everyone who works for or with Susan Birth has some responsibility for ensuring data is collected, stored and handled appropriately. Each person that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles. These people have key areas of responsibility: Susan Birth in her role as Data Protection Officer is ultimately responsible for ensuring that she meets her art business’ legal obligations. The Data Protection Officer is responsible for: ∙ Keeping 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 employees/helpers and anyone else covered by this policy. ∙ Dealing with requests from individuals to see the data that Susan Birth holds about them (also called ‘subject access requests’) ∙ Checking and approving any contracts or agreements with third parties that may handle sensitive data.
As the IT Authority, Susan Birth, is responsible for: ∙ Ensuring all systems, services and equipment used for storing data meet acceptable and proportionate security standards ∙ Performing regular checks and scans to ensure security hardware and software is functioning properly ∙ Evaluating any third party services that may possibly be used to store or process data. For instance, cloud computing services. As the Marketing Authority, Susan Birth is responsible for: ∙ Approving any data protection statements attached to communications such as emails and letters ∙ Addressing any data protection queries from journalists or media outlets such as newspapers ∙ Where necessary, working with other employees/helpers to ensure marketing initiatives abide by data protection principles.
General Employee/Helper 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/helpers can request it ∙ Susan Birth will if necessary provide training to all employees/helpers to help them understand their responsibilities when handling data ∙ Employees/helpers should keep all data secure, by taking sensible precautions and following the guidelines below ∙ In particular, strong passwords must be used and should never be shared ∙ Personal data should not be disclosed to unauthorised people, either within the art business 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/helpers should request help from their manager or the data protection officer if they are unsure about any aspect of data protection
These regulations describe how and where data should be safely stored. Questions about storing data safely can be directed to Susan Birth. 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 normally stored electronically but has been printed out in hard copy: ∙ When not required, the paper or files should be kept in a lockable filing cabinet ∙ Employees/helpers should make sure paper and printouts are not left where unauthorised people could see them, such as, on a printer ∙ Data printouts should 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/helpers ∙ If data is stored on removable media (such as, a CD/DVD or memory drive), these should be kept locked away securely when not in use ∙ Data should only be stored on designated drives and servers, and should only be uploaded to the art business’ approved cloud computing services ∙ Data should be backed up regularly. Those backups should be tested frequently, in line with the art business’ standard backup procedures (if available) ∙ Data should never be saved directly to laptops or other mobile devices, such as, 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 the artist Susan Birth unless the business can make use of it. However, when personal data is accessed and used it is at this point where the greatest risk of loss, corruption or theft may occur: ∙ When working with personal data, employees/helpers 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 ∙ Personal data should never be transferred outside of the European Economic Area ∙ Employees/helpers should not save copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires Susan Birth to take reasonable steps to ensure data is kept accurate and up to date. It is essential that personal data is accurate. It is the responsibility of Susan Birth and all employees/helpers 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. Susan Birth and employees/helpers should not create any unnecessary additional data sets ∙ Susan Birth and employees/helpers should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call ∙ Susan Birth will make it easy for data subjects to update the information her art business holds about them. Such as, via her website ∙ Data should be updated as inaccuracies are discovered. Such as, if a customer can no longer be reached on their stored telephone number, it should be removed from the database ∙ It is the Marketing Authority’s responsibility to ensure marketing databases are checked against industry suppression files annually.
Subject access requests
All individuals who are the subject of personal data held by Susan Birth are entitled to: ∙ Ask what information her art business holds about them and why ∙ Ask how to gain access to it ∙ Be informed how to keep it up to date ∙ Be informed how Susan Birth is meeting her data protection obligations. If an individual contacts the art business requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email, addressed to the Data Protection Officer (DPO) – Susan Birth. The DPO can supply a standard request form, although individuals do not have to use this. The DPO will aim to provide the relevant data within 14 days of the request and payment. The DPO will always verify the identity of anyone making a subject access request before handing over any information.
Disclosing data for other reason
In certain circumstances, GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Susan Birth will disclose requested data. However, the DPO will ensure the request is legitimate, seeking assistance from the Owners and from legal advisers where necessary.
Susan Birth 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 ∙ To these ends, Susan Birth has a privacy statement, setting out how data relating to individuals is used ∙ This is available on request. A version of this statement is also available on the art business website.
We may gather and use certain information about individuals in order to provide products and services and to enable certain functionality on this website. We collect information to better understand how visitors use this website and to return timely, relevant information to them.
What data we may gather
Via this website we may collect the following information: ∙ Name ∙ Contact information including email address ∙ Demographic information, such as postcode, preferences and interests ∙ Website usage data ∙ Other information relevant to client enquiries ∙ Other information pertaining to special offers and surveys
How we use this data
Collecting this data helps us understand what you are looking for from the art business, enabling us to deliver improved products and services. Specifically, we may use data: ∙ For our own internal records ∙ To improve the products and services we provide ∙ To contact you in response to a specific enquiry ∙ To customise the website for you ∙ To send you promotional emails about products, services, offers and other things we think might be relevant to you ∙ To send you promotional mailings or to call you about products, services, offers and other things we think might be relevant to you ∙ To contact you via email, telephone or mail for market research purposes.
Cookies and how we use them
If you have agreed that we can use your information for marketing purposes, you can change your mind easily, via one of these methods: ∙ Send an email to firstname.lastname@example.org ∙ Write to: Susan Birth, 37 Nunnery Lane, Worcester, Worcestershire, WR5 1RQ, United Kingdom. We will never lease, distribute or sell your personal information to third parties unless we have your permission or the law requires us to do so.
Any personal information we hold about you is stored and processed under our data protection policy, in line with the General Data Protection Regulation (GDPR) of May 2018.
We will always hold your information securely. To prevent unauthorised disclosure or access to your information, we have implemented strong physical and electronic security safeguards. We also follow stringent procedures to ensure we work with all personal data in line with the General Data Protection Regulation (GDPR) of May 2018.
Links from our site
Our website may contain links to other websites. Please note that we have no control of websites outside of the susanbirth domain. If you provide information to a website to which we link, we are not responsible for its protection and privacy. Always be wary when submitting data to websites. Read the site’s data protection and privacy policies fully.