Our Data Protection Policy

Statement for the financial year 2023-2024

Working in the digital industry, we need to gather and use certain information about individuals.

These individuals can include Bravand customers, suppliers, business contacts, employees and other people we have a relationship with or may need to contact.

There may also be times when we need to gather and use certain information about individuals that are our clients’ customers, suppliers, business contacts, employees and other people they have a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet our data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures Bravand:

• Complies with data protection law and follows good practice
• Protects the rights of employees and other people working on behalf of Bravand, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach.

Data protection law

The Data Protection Act 2018 describes how organisations — including Bravand — 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 is underpinned by eight important principles. These say that personal data must:

• Be fairly and lawfully processed.
• Be processed for limited purposes.
• Be adequate, relevant and not excessive.
• Be accurate.
• Not be kept for longer than is necessary.
• Be processed in line with your rights.
• Be secure.
• Not be transferred to other countries without adequate protection.

People, risks and responsibilities

Policy scope
This policy applies to:

• The head office of Bravand
• All remote locations that employees and other people working on behalf of Bravand work from
• All employees, associates and volunteers of Bravand
• All contractors, suppliers and other people working on behalf of Bravand

It applies to all data that Bravand holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 2018. This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• …plus any other information relating to individuals
  

Data protection risks

This policy helps to protect Bravand 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 Bravand uses data relating to them.
• Reputational damage: for instance, Bravand could suffer if hackers successfully gained access to sensitive data.

Responsibilities

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

Each team that handles personal data ensures 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 Bravand meets its legal obligations.
• The director, Ross Musgrove, is responsible for:
  - Keeping the board 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 and anyone else covered by this policy.
  - Dealing with requests from individuals to see the data Bravand holds about them (also called ‘subject access requests’).
  - Checking and approving any contracts or agreements with third parties that may handle Bravand’s sensitive data.
  - Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
  - Performing regular checks and scans to ensure security hardware and software is functioning properly.
  - Evaluating any third-party services Bravand is considering using to store or process data. For instance, cloud computing services.
  - Approving any data protection statements attached to communications such as emails and letters.
  - Addressing any data protection queries from journalists or media outlets like newspapers.
  - Where necessary, working with others to ensure marketing initiatives abide by data protection principles.
  - Ensuring that all data provided by individuals outside the organisation has been done on a voluntary ‘opt-in’ basis and that individuals have the right to ‘opt-out’ at any time.

General guidelines

• The only people able to access data covered by this policy are those who need it for their work.
• Data is not shared informally. When access to confidential information is required, it must be requested from the Senior Management Team.
• Bravand provides training to all employees and other people working on behalf of Bravand, to help them understand their responsibilities when handling data.
• Employees and other people working on behalf of Bravand keep all data secure, by taking sensible precautions and following the guidelines in this policy.
• In particular, strong passwords are used and never shared.
• Personal data is not disclosed to unauthorised people, either within the company or externally.
• Data is regularly reviewed and updated if it is found to be out of date. If no longer required, it is deleted and disposed of.
• Employees and other people working on behalf of Bravand request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data storage

These rules describe how and where data is safely stored. Questions about storing data safely can be directed to Ross Musgrove (07799 885 950 / ross@bravand.com).

When data is stored on paper, it is 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 are kept in a locked drawer or filing cabinet.
• Employees and other people working on behalf of Bravand make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
• Data printouts are shredded and disposed of securely when no longer required.

When data is stored electronically, it is protected from unauthorised access, accidental deletion and malicious hacking attempts:

• Data is protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like a CD or DVD), it is kept locked away securely when not being used.
• Data is only stored on designated drives and servers, and is only uploaded to approved cloud computing services.
• Servers containing personal data are sited in a secure location, away from general office space.
• Data is backed up frequently. Those backups are tested regularly, in line with Bravand’s standard backup procedures.
• Data is never saved directly to laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data are protected by approved security software and a firewall.

Data use

Personal data is of no value to Bravand 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 and other people working on behalf of Bravand ensure the screens of their computers are always locked when left unattended.
• Personal data is not shared informally. In particular, it is never sent by email, as this form of communication is not secure.
• Data is encrypted before being transferred electronically. Ross Musgrove can explain how to send data to authorised external contacts.
• Personal data is never transferred outside of the UK.
• Employees do not save copies of personal data to their own computers and always access and update the central copy of any data.

Data accuracy

The law requires Bravand 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 Bravand puts into ensuring its accuracy.

It is the responsibility of all employees and other people working on behalf of Bravand who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

• Data is held in as few places as necessary. Employees and other people working on behalf of Bravand do not create any unnecessary additional data sets.
• Employees and other people working on behalf of Bravand take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• Bravand will make it easy for data subjects to update the information we hold about them. For instance, via our website.
• Data is updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it is removed from the database.
• It is Ross Musgrove’s responsibility to ensure marketing databases are checked against industry suppression files every six months. 

Destroying data

When data is no longer needed, it is destroyed permanently and securely. The following sets out how we ensure it’s no longer usable by Bravand, or anyone else:

• Paper documents are shredded
• Electronic records are deleted, then removed from the recycle bin (or similar), emails and other electronic communications containing copies of records are also deleted
  - It may become necessary to use secure deletion software or seek specialist IT advice. This will be reviewed by Ross Musgrove on an ongoing basis and questions relating to this can be directed to Ross.

Subject access requests

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

• Ask what information Bravand holds about them and why.
• Ask how to gain access to it.
• Be informed how to keep it up to date.
• Be informed how Bravand is meeting its data protection obligations.

If an individual contacts Bravand requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to Ross Musgrove at ross@bravand.com. Ross Musgrove can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. Ross Musgrove will aim to provide the relevant data within 14 days.

Ross Musgrove will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

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

Under these circumstances, Bravand will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from Bravand’s legal advisers where necessary.

Providing information

Bravand 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, Bravand has a privacy policy, setting out how we use data relating to individuals. This is available on request, and a version is also available at www.bravand.com/privacy.

Key details
Policy prepared by: Ross Musgrove
Approved on: 28 April 2020
Last reviewed on: 25 March 2023
Next review date: 25 March 2024

Contact
Ross Musgrove, Director
07799 885 950
ross@bravand.com