Detailing Driven is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out the organisation’s commitment to data protection, and individual rights and obligations in relation to personal data. This policy applies to the personal data of employees, and suppliers referred to as HR related personal data. [This policy does not apply to the personal data of clients or other personal data processed for business purposes].

Detailing Driven has appointed David Price-Evans its data protection officer. His role is to inform and advise Detailing Driven on its data protection obligations. He can be contacted at david@detailingdriven.com. Questions about this policy, or requests for further information, should be directed to the data protection officer.

DEFINITIONS

“Personal data” is any information that relates to a living individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing, or destroying it.

“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and genetic and biometric data. “Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.

DATA PROTECTION PRINCIPLES

Detailing Driven processes HR-related personal data in accordance with the following data protection principles:

• • Detailing Driven processes personal data lawfully, fairly and in a transparent manner.

• • Detailing Driven collects personal data only for specified, explicit and legitimate purposes.

• • Detailing Driven processes personal data only where it is adequate, relevant, and limited to what is necessary for the purposes of processing.

• • Detailing Driven keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.

• • Detailing Driven keeps personal data only for the period necessary for processing.

• • Detailing Driven adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction, or damage.

• • Detailing Driven tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons.

• • Where Detailing Driven relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.

• • Where Detailing Driven processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data.

• • Detailing Driven will update HR-related personal data promptly if an individual advises that his/her in- formation has changed or is inaccurate.

• • Personal data gathered during the [employment, worker, contractor or volunteer relationship, or apprenticeship or internship] is held in the individual’s personnel file (in hard copy or electronic format, or both), and on HR systems. The periods for which Detailing Driven holds HR-related personal data are contained in its privacy notices to individuals.

• • Detailing Driven keeps a record of its processing activities in respect of HR-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

INDIVIDUAL RIGHTS

As a data subject, individuals have several rights in relation to their personal data.

SUBJECT ACCESS REQUESTS

Individuals have the right to make a subject access request. If an individual makes a subject access request, Detailing Driven will tell him/her:

• whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual.

• to whom his/her data is or may be disclosed, including to recipients located outside the European Eco- nomic Area (EEA) and the safeguards that apply to such transfers.

• for how long his/her personal data is stored (or how that period is decided).

• his/her rights to rectification or erasure of data, or to restrict or object to processing.

• his/her right to complain to the Information Commissioner if he/she thinks Detailing Driven has failed to comply with his/her data protection rights; and

• whether or not Detailing Driven carries out automated decision-making and the logic involved in any such decision-making.

Detailing Driven will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically unless he/she agrees otherwise.

If the individual wants additional copies, Detailing Driven will charge a fee, which will be based on the ad- ministrative cost to Detailing Driven of providing the additional copies.

To make a subject access request, the individual should send the request to david@starfishpeople.com. In some cases, Detailing Driven may need to ask for proof of identification before the request can be processed. Detailing Driven will inform the individual if it needs to verify his/her identity and the documents it requires.
Detailing Driven will normally respond to a request within a period of one month from the date it is received. In some cases, such as where Detailing Driven processes large amounts of the individual’s data, it may respond within three months of the date the request is received. Detailing Driven will write to the individual within one month of receiving the original request to tell him/her if this is the case.

If a subject access request is manifestly unfounded or excessive, Detailing Driven is not obliged to comply with it. Alternatively, Detailing Driven can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which Detailing Driven has already respond- ed. If an individual submits a request that is unfounded or excessive, Detailing Driven will notify him/her that this is the case and if it will respond to it.

OTHER RIGHTS

Individuals have several other rights in relation to their personal data. They can require Detailing Driven to:

RECTIFY INACCURATE DATA:

• stop processing or erase data that is no longer necessary for the purposes of processing.

• stop processing or erase data if the individual’s interests override the organisation’s legitimate. grounds for processing data (where Detailing Driven relies on its legitimate interests as a reason for processing data).

• stop processing or erase data if processing is unlawful; and

• stop processing data for a period if data is inaccurate or if there is a dispute about if the individual’s interests override the organisation’s legitimate grounds for processing data.

To ask Detailing Driven to take any of these steps, the individual should send the request to david@detailingdriven.com.

DATA SECURITY

Detailing Driven takes the security of HR-related personal data seriously. Detailing Driven has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse, or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties. Data we hold is encrypted and all personal computers allowing staff to access personal data also have password protection.

Where Detailing Driven engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

DATA BREACHES

If Detailing Driven discovers that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell a affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

INTERNATIONAL DATA TRANSFERS

Detailing Driven will not transfer HR-related personal data to countries outside the EEA.

INDIVIDUAL RESPONSIBILITIES

Individuals are responsible for helping Detailing Driven keep their personal data up to date. Individuals should let Detailing Driven know if data provided to Detailing Driven changes, for example if an individual moves to a new house or changes his/her bank details. Individuals who have access to personal data are required:
• to access only data that they have authority to access and only for authorised purposes.

• not to disclose data except to individuals (whether inside or outside the organisation) who have appropriate authorisation.

• to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction).

• not to remove personal data, or devices containing or that can be used to access personal data, from the organisation’s premises without adopting appropriate security measures (such as encryption or pass- word protection) to secure the data and the device;

• not to store personal data on local drives or on personal devices that are used for work purposes; and

• to report data breaches of which they become aware to David Price-Evans immediately.

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the organisation’s disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross mis- conduct and could lead to dismissal without notice.

TRAINING

Detailing Driven will provide training to all individuals about their data protection responsibilities as part of the induction process and at regular intervals thereafter. Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.