1. Introduction

RM Contractors needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people the company 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 comply with the law.

2. Why this policy exists

The data protection policy ensures RM Contractors:

• 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 individual’s data
• Protects itself from the risks of a data breach
  

3. Data protection law

The Data Protection Act 1998 describes how organisations – including RM Contractors – 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 1998 is underpinned by eight important principles. These say that personal data must:

1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.
   

4. People, risks and responsibilities

POLICY SCOPE

This policy applies to:

• RM Contractors Head Office
• All RM Contractors Construction Sites
• All RM Contractors staff
• All Contractors, suppliers and other people working on behalf of RM Contractors.
  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 include:
• Names of Individuals
• Postal Addresses
• Email Addresses
• Telephone Numbers
• Any other information relating to individuals
  
  DATA PROTECTION RISKS
  This policy helps protect RM Contractors 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 the company uses
  data relating to them.
• Reputational Damage – For instance, the company could suffer if hackers successfully gained access to
  sensitive data.
  
  RESPONSIBILITES
  Everyone who works for or with RM Contractors 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:
  The Directors are ultimately responsible for ensuring that RM Contractors meets its obligations.

The Office Manager at RM Contractors is responsible for:

• Keeping the directors updated about data protection responsibilities, risks and issues.
• Reviewing all data protection procedures and related policies, in line with agreed schedule.
• Handling data protection questions from staff and anyone covered by this policy.
• Dealing with requests from individuals to see the data RM Contractors holds about them (also called subject to request).
• Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
• The designated IT Manager for RM Contractors is responsible for:
• Ensuring all systems, services and equipment used for storing data meets acceptable security standards.
• Perform regular checks and scans to ensure security hardware and software is functioning properly.
• Evaluating any third-party services, the company is considering using to store or process data. For instance, cloud computing services
  

5. General staff 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 is required to confidential information employees can request it from their line managers.
• Employees 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 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 if they re unsure about any aspect of data protection.

6. Data storage

These rules described how and where data should be safely stored. Questions about storing data can be directed Office or IT Manager.

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 reason:

• When not required, the paper or files should be kept in a locked drawer or filling cabinet.
• 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 CD, USB Stick), 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 service.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently. Those backups should be tested regularly, in line with 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 must be protected by approved security software and a
  firewall

7. Data use

Personal data is of no value to RM Contractors 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 and 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.
• 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.

8. Data accuracy

The law requires RM Contractors 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 RM Contractors 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.

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional datasets.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• RM Contractors will make it easy for data subjects to update information RM Contractors 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.

9. Subject access requests

All individuals who are the subject of personal data held by RM Contractors are entitled to:

• 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 any 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 Office Manager at
  info@rmcontractors.co.uk.
  Individuals will be charged £15 per subject access request. The office manager will aim to prove the relevant
  data within 14 days of receiving the request.
  The office manager will always verify the identity of anyone making a subject access request before handing over any information.

10. Disclosing data for other reasons

In certain circumstances, the Data Protection Act 1998 allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, RM Contractors will disclose requested data. However, the office manager will ensure the request is legitimate, seeking assistance from the Directors and from the companies’ legal advisers where necessary.

11. Providing information

RM Contractors 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

Signed: Christopher Moen

Position: Managing Director

Policy last updated: January 2022