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Data protection risks

This policy helps to protect Melin Tregwynt Ltd from data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, you are free to choose how we use data relating to you.
• Reputational damage. For instance, we could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with Melin Tregwynt Ltd has some responsibility for ensuring data is collected, stored and handled appropriately.

Anyone handling 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 board of directors is ultimately responsible for ensuring that Melin Tregwynt Ltd meets its legal obligations.
• The designated Data Protection Manager is responsible for:
  • Keeping colleagues 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 staff and anyone else covered by this policy.
  • Dealing with requests from individuals to see the data Melin Tregwynt Ltd holds about them (also called ‘subject access requests’).
  • Checking third parties’ Data Protection policies.
  • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
  • Checking our IT services to ensure security hardware and software.
  • Evaluating any third-party services, the company is considering using to store or process data. For instance, cloud computing services.

 

• Where necessary, working with colleagues to ensure marketing initiatives abide by data protection principles.

General Guidelines

• The only people able to access data covered by this policy should be those who need it for their work.
• Data WILL not be shared informally. When access to confidential information is required, employees can request it from the Directors.
• Melin Tregwynt Ltd will provide training to all employees to help them understand their responsibilities when handling data.
• Employees WILL keep all data secure by using password and locked cabinets, taking sensible precautions and following the guidelines.
• When staff leave the company, entry codes must be changed. Their computer login must be set inactive and denied access.
• In particular, strong passwords must be used and they should be secured and never be shared.
• Personal data should not be disclosed to unauthorised people, either within the company or externally.
• Data WILL 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 safely.
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Storage of Data

Questions about storing data safely can be directed to the responsible Director.

Our developers and webhosts store basic server access logs for debugging, security and service review to perform maintenance and occasional debugging.

When data is stored on paper, it will 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 will be kept in a locked drawer or filing cabinet.
• Employees must make sure paper and printouts are not left where unauthorised people could see them.
• Data printouts must 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 will be protected by strong passwords that are changed when staff is leaving and never shared between employees.
• If data is stored on removable media (like a CD, DVD, USB key or backup tape), these should be kept locked away securely when not being used.
• Data should never be saved directly to computers, laptops or other mobile devices like tablets or smart phones.
• Data should only be stored on designated drives and servers so not on computers “desktop”, and should only be uploaded to approved cloud computing services.
• Servers containing personal data are sited in a secure location and password protected only accessible by our IT service providers.
• Data is backed up daily. Those backups must be secure and tested daily.
• Servers and computers containing data are protected by approved security software and a firewall.

Use of data

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• Internal record keeping.
• To analyse the use of the Melin Tregwynt website.
• To improve Melin Tregwynt's products and services.
• For follow up by phone or email, to people who have purchased goods from us as part of Melin Tregwynt's customer care procedures.
• With your consent, to send promotional e-mail about new products, special offers and events at Melin Tregwynt. You can withdraw your consent at any time by calling 01348 891 644, emailing mailorder@melintregwynt.co.uk or visiting our subscription centre
• To pass your phone number to a carrier service if needed.
• With your consent, we may also from time to time use your information to contact you for market research purposes by e-mail.

We will not sell, distribute or lease your personal information to third parties unless required to do so by law.

Melin Tregwynt may disclose your personal information to Melin Tregwynt's service providers who assist us with the operation of the website (for example, by administering or hosting the site or, with your consent, sending you promotional communications), but they will act only on Melin Tregwynt’s behalf and under strict conditions of confidentiality and security.

Personal data is of no value to Melin Tregwynt Ltd 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 or 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 encrypted.
• In the event that data is transferred to a Third Party, it must be encrypted before being transferred electronically. No password are to be communicated by email but over the phone. Alternatively, if available, a secure data upload will be used.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Accuracy of data

The law requires Melin Tregwynt Ltd to take reasonable steps to ensure data is kept accurate and up to date.

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 data sets.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• Melin Tregwynt Ltd will make it easy for you to update the information we hold about you. For instance, you can visit our website to update your account and your subscription preference or you can call us on 01348891644.
• 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.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files.
• When catalogues are returned to us the data used must be deleted securely.

Subject Access Requests

All individuals who are the subject of personal data held by Melin Tregwynt Ltd 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 an 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 data controller. The data controller can supply a standard request form, although individuals do not have to use this.

The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Other reasons for disclosing data

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

Under these circumstances, Melin Tregwynt Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the Directors and from the company’s legal advisers where necessary.

Providing Information

Melin Tregwynt Ltd 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, this document sets out how data relating to you is used by Melin Tregwynt Ltd.