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This document sets out the obligations of Sendmoneyhome.co.uk (“the Company”) with regard to data protection and the rights of people with whom it works in respect of their personal data under the Data Protection Act 1998 (“the Act”).
This Policy shall set out procedures which are to be followed when dealing with personal data. The procedures set out herein must be followed by the Company, its employees, contractors, agents, consultants, partners or other parties working on behalf of the Company.
The Company views the correct and lawful handling of personal data as key to its success and dealings with third parties. The Company shall ensure that it handles all personal data correctly and lawfully.
2. The Data Protection Principles
This Policy aims to ensure compliance with the Act. The Act sets out eight principles with which any party handling personal data must comply. All personal data:
2.1 Must be processed fairly and lawfully (and shall not be processed unless certain conditions are met);
2.2 Must be obtained only for specified and lawful purposes and shall not be processed in any manner which is incompatible with those purposes;
2.3 Must be adequate, relevant and not excessive with respect to the purposes for which it is processed;
2.4 Must be accurate and, where appropriate, kept up-to-date;
2.5 Must be kept for no longer than is necessary in light of the purpose(s) for which it is processed;
2.6 Must be processed in accordance with the rights of data subjects under the Act;
2.7 Must be protected against unauthorised or unlawful processing, accidental loss, destruction or damage through appropriate technical and organisational measures; and
2.8 Must not be transferred to a country or territory outside of the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
3. Rights of Data Subjects
Under the Act, data subjects have the following rights:
4. Personal Data
Personal data is defined by the Act as data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.
The Act also defines “sensitive personal data” as personal data relating to the racial or ethnic origin of the data subject; their political opinions; their religious (or similar) beliefs; trade union membership; their physical or mental health condition; their sexual life; the commission or alleged commission by them of any offence; or any proceedings for any offence committed or alleged to have been committed by them, the disposal of such proceedings or the sentence of any court in such proceedings.
The Company only holds personal data which is directly relevant to its dealings with a given data subject. That data will be held and processed in accordance with the data protection principles and with this Policy. The following data may be collected, held and processed by the Company from time to time:
5. Processing Personal Data
Any and all personal data collected by the Company (including that detailed in Section 4 of this Policy) is collected in order to ensure that the Company can facilitate efficient transactions with third parties including, but not limited to, its customers, partners, associates and affiliates and efficiently manage its employees, contractors, agents and consultants. Personal data shall also be used by the Company in meeting any and all relevant obligations imposed by law.
Personal data may be disclosed within the Company. Personal data may be passed from one department to another in accordance with the data protection principles and this Policy. Under no circumstances will personal data be passed to any department or any individual within the Company that does not reasonably require access to that personal data with respect to the purpose(s) for which it was collected and is being processed.
The Company shall ensure that:
6. Data Protection Procedures
The Company shall ensure that all of its employees, contractors, agents, consultants, partners or other parties working on behalf of the Company comply with the following when processing and / or transmitting personal data:
7. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding and processing of personal data:
8. Access by Data Subjects
A data subject may make a subject access request (“SAR”) at any time to see the information which the Company holds about them.
Upon receipt of a SAR the Company shall have a maximum period of 40 days within which to respond. The following information will be provided to the data subject:
9. Notification to the Information Commissioner’s Office
As a data controller, the Company is required to notify the Information Commissioner’s Office that it is processing personal data. The Company is registered in the register of data controllers.
Data controllers must renew their notification with the Information Commissioner’s Office on an annual basis. Failure to notify constitutes a criminal offence.
Any changes to the register must be notified to the Information Commissioner’s Office within 28 days of taking place.
The Designated Officer shall be responsible for notifying and updating the Information Commissioner’s Office.
10. Implementation of Policy
This Policy shall be deemed effective as of 06/11/2012. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
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Send Money Home 324 Southend Road, Wickford, Essex SS11 8QS