BARTON SMITH LOCK AND SAFE

DATA PROTECTION POLICY

Introduction

BARTON SMITH LOCK AND SAFE privacy and data protection rights are very important to us.

Data Protection is the safeguarding of the privacy rights of individuals in relation to the processing of personal data, in both paper and electronic format. The Data Protection Acts 1988 and 2003 (the “Data Protection Acts”) lay down strict rules about the way in which personal data and sensitive personal data are collected, accessed, used and disclosed. The Data Protection Acts also permit individuals to access their personal data on request, and confer on individuals the right to have their personal data amended if found to be incorrect.

This document outlines Barton Smith Lock & Safes policy to help ensure that we comply with the Data Protection Acts.

Inquiries about this Data Protection Policy should be made to:

Manager, Barton Smith Lock and Safe, Millennium House, Stephen Street, Sligo

Data Protection Policy

Purpose of this policy

This policy is a statement of Barton Smith’s commitment to protect the rights and privacy of individuals in accordance with the Data Protection Acts.

Individuals’ Responsibilities

Any staff member of Barton Smith Lock & Safe who is involved in the collection, storage or processing of personal data has responsibilities under the legislation:.

Any staff member involved in the processing/storing of personal data should make sure;

to obtain and process personal data fairly.
to keep such data only for explicit and lawful purposes.
to disclose such data only in ways compatible with these purposes
to keep such data safe and secure.
to keep such data accurate, complete and up-to-date.
to ensure that such data is adequate, relevant and not excessive.
to retain such data for no longer than is necessary for the explicit purpose.
to give, on request, a copy of the data to the individual to whom they relate, such a request is known as an ACCESS REQUEST (sample access request letter is attached in Appendix II)

Any data access requests received should be forwarded immediately to the Manager, Compliance & Information Management. A fee of €6.35 applies to any application for information under the Data Protection Acts.

Individual Rights

The individuals for whom Barton Smith Lock & Safe stores personal data have the following rights:

to have their personal data obtained and processed fairly
to have personal data kept securely and not illegitimately disclosed to others.
to be informed of the identity of the Data Controller and of the purpose for which the information is held.
to get a copy of their personal data.
to have their personal data corrected or deleted if inaccurate.
to prevent their personal data from being used for certain purposes: for example, one might want to have the data blocked for research purposes where it is held for other purposes.
under Employment Rights, not to be forced to disclose information to a prospective employer. No one can force another person to make an access request, or reveal the results of an access request, as a condition of recruitment, employment or provision of a service. Where vetting for employment purposes is necessary, this can be facilitated where the individual gives consent to the data controller to release personal data to a third party.
It should be noted that under the Freedom of Information Act 2014, records containing personal information may be released to a third party, where the public interest so requires.

Principles of the Acts

Barton Smith Lock & Safe will administer its responsibilities under the legislation in accordance with the eight stated data protection principles outlined in the Act as follows:

1. Obtain and process information fairly.

Barton Smith Lock & Safe will obtain and process personal data fairly and in accordance with the fulfilment of its functions.

2. Keep data only for one or more specified, explicit and lawful purposes.

Barton Smith Lock & Safe will keep data for purposes that are specific, lawful and clearly stated and the data will only be processed in a manner compatible with these purposes.

3. Use and disclose data only in ways compatible with these purposes.

Barton Smith Lock & Safe will only disclose personal data that is necessary for the purpose/s or compatible with the purpose/s for which it collects and keeps the data.

4. Keep data safe and secure

Barton Smith Lock & Safe will take appropriate security measures against unauthorised access to, or alteration, disclosure or destruction of, the data and against their accidental loss or destruction. Barton Smith Lock & Safe is aware that high standards of security are essential for all personal data.

5. Keep data accurate, complete and up-to-date.

Barton Smith Lock & Safe will have procedures that are adequate to ensure high levels of data accuracy. Barton Smith Lock & Safe will examine the general requirement to keep personal data up-to-date. Barton Smith Lock & Safe will put in place appropriate procedures to assist staff in keeping data up-to-date.

6. Ensure that data are adequate, relevant and not excessive.

Personal data held by Barton Smith Lock & Safe will be adequate, relevant and not excessive in relation to the purpose/s for which it is kept.

7. Retain data for no longer than is necessary for the purpose or purposes for which they are kept.

Barton Smith Lock & Safe will have a policy on retention periods for personal data and disposal of said data by shredding.

8. Give a copy of his/her personal data to that individual, on request

Barton Smith Lock & Safe will have procedures in place to ensure that data subjects can exercise their rights under the Data Protection legislation.

Roles/Responsibilities of Barton Smith Lock & Safe

Barton Smith Lock & Safe has overall responsibility for ensuring compliance with the Data Protection legislation. However, all employees of Barton Smith Lock & Safe who collect and/or control the contents and use of personal data are also responsible for compliance with the Data Protection legislation. Barton Smith Lock & Safe will provide support, assistance, advice and training to all relevant employees.

Contact Person: Manager of Barton Smith Lock & Safe

Compliance Person: Manager, Barton Smith Lock & Safe

Procedures and Guidelines

This policy supports the provision of a structure to assist Barton Smith Lock & Safe compliance with the Data Protection legislation, including the provision of best practice guidelines and procedures in relation to all aspects of Data Protection.

Review

This Policy will be reviewed regularly in light of any legislative or other relevant indicators.

Appendix I

Definitions

The following definitions are taken from the Data Protection Acts 1998 and 2003

Full copies of the act are available at the Data Protection Commissioner web site www.dataprotection.ie.

Personal data means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the data controller;

Sensitive personal data means personal data as to -

(a) The racial or ethnic origin, the political opinions or the religious or

philosophical beliefs of the data subject.

(b) whether the data subject is a member of a trade-union.

(d) the commission or alleged commission of any offence by the data subject, or

(e) any proceedings for an offence committed or alleged to have been committed

by the data subject, the disposal of such proceedings or the sentence of any court

in such proceedings.

Appendix II

Sample Letter

Please see below, sample wording for letter to give permission for data to be held under the Data Protection Acts 1988 and 2003.

GDPR Form

To comply with GDPR regulations please complete (placing a tick) to the following statements by giving consent for only Barton Smith Lock and Safe to the

o Use of your e-mail address

o Storage of your e-mail address

o Use of your postal address

o Storage of your postal address

o To receive statements to your e-mail address

o To receive correspondence to your e-mail address

Signature _________________

Date _________________

Company Name _______________________________