General Data Protection Regulations of Solent Photography Ltd 2019

      I.         Context and overview key details

Policy prepared by - Martin Carroll

Policy review date - Sept 2020

Company Name: Solent Photography Ltd

Company Registration Number - 07745852 

     II.         Introduction

Solent Photography Ltd (also known to schools as Keepsakes/Keepsakes Photography) needs to gather and use certain information about individuals in the course of conducting their business. These can include customers, suppliers, business contacts, employees and other people the business has a relationship with or may need to contact. It can include names, addresses and other contact details. This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law. 

   III.         Why this policy exists

This General Data Protection Regulation Policy ensures that Solent Photography Ltd:

• Follows good practice and complies with the data protection law

• Protects the rights of staff, customers and partners

• Is open about how it stores and processes individuals’ data

• Protects itself from the risks of a data breach 

  IV.         General Data Protection Regulation

The General Data Protection Regulation describes how organisations — including Solent Photography Ltd — 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.

We are Data Protection Registered with the Information Commissioners Office (ICO) reference number A8492729.

GDPR is underpinned by six important principles. These say that personal data must be:

1) Processed lawfully, fairly and in a transparent manner in relation to individuals

2) Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be incompatible with the initial purposes

3) Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed

4) Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay

5) Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals

6) Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. 

      V.       Data protection risks

This policy helps to protect Solent Photography Ltd from 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 the company uses data relating to them.

• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data. 

     VI.       People, risks and responsibilities policy scope

This policy applies to:

• The head office of Solent Photography Ltd

• All staff and volunteers of Solent Photography Ltd

• All contractors, suppliers and others working on behalf of Solent Photography Ltd

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the General Data Protection Regulation. This can include

• Names of individuals

• Postal addresses

• Email addresses

• Telephone numbers

• Photographs

• plus any other information relating to individuals 

   VII.       Responsibilities

Everyone who works for or with Solent Photography Ltd has some responsibility for ensuring data is collected, stored and handled appropriately. Everyone who handles personal data must ensure that it is handled and processed in line with this policy and GDPR principles.

The Company Director and Data Protection Officer, Martin Carroll, is solely responsible for Solent Photography Ltd meeting all its legal obligations including:

• Ensuring, reviewing and keeping up to date all data protection procedures, systems  and policies

• Handling data protection questions from relevant parties including customers and suppliers

• Dealing with subject access requests from customers (those wishing to see what data we hold about them)

      V.       Information we may gather and how we use it

Solent Photography Ltd work closely within school PE departments adhering to the schools’ own policies regarding the taking of photographs. We take individual portrait photographs of pupils using digital cameras, copies of which are offered under no obligation to parents/carers to purchase.

Whilst working in the school we often take additional action/team photographs for the school to use in the promotion of the PE department. For example display posters for open evenings etc.

All digital images are stored on encrypted local hard drives and are stored only for a period of time where they are to be used. After this they are deleted. They are never stored on cloud based services.

Any images supplied by us to the school are for the schools own use and are subject to their own privacy and data policies.

In order to complete customer orders we may collect names, addresses and contact details. We take privacy very seriously and only use your information to administer any orders we receive. No information will ever be used for any marketing purpose. No details will be shared anywhere or at anytime unless we are obliged to by law.

Cheque/cash orders and payments that are handed in to school are only collected by Martin Carroll and are securely stored for a period of time where they are to be used.

If orders are placed and paid for online by debit or credit card, details are collected by a third party organisation. Therefore we do not process card payment information and do not store it ourselves. Our payment website uses secure HTTPS connections and our checkout is PSD2 and Strong Customer Authentication (SCA) compliant.

In order to provide the services on our payment website we use:

• a website template hosted by Squarespace.com

• checkout and payment services are provided by Stripe (Stripe.com)

These providers have their own privacy policy and terms available on their respective websites. We are not responsible for the policies of any third party service.

Any order information provided to/gathered by us offline and any hard copies of any data are kept secure and shredded as soon as any orders are completed. Hard copy data includes: order forms, printed emails, photographs etc.

Orders posted to home are dispatched containing no relatable order information other than the shipping name and address.

We aim to ensure that individuals are aware how their data is being used and how to exercise their rights. Should you have any queries about our GDPR policy or how we may use your personal information please email us at solentphoto@aol.com

      V.       Data Retention

We collect and use personal data to administer orders and deliver photographs. We also use it to anticipate and resolve queries.

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Data Protection Officer. We do not disclose this data to any third parties.

When data is stored on paper, it is for only a brief period to complete an order and is kept secure. 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.

• 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 must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

• Data is protected by strong passwords that are changed regularly and never shared.

• Data is only stored on password protected drives.

• Data is backed up frequently. Those backups are tested regularly, in line with the company’s standard backup procedures.

• Data is never saved directly to laptops or other mobile devices like tablets or smart phones.

Personal data is of no value to Solent Photography 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:

• Personal data is not shared informally.

• Data must be shared only with authorised contacts and where possible encrypted

• Personal data should never be transferred outside of the European Economic Area.

The law requires Solent Photography Ltd 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 Solent Photography Ltd should put into ensuring its accuracy. 

     VI.       Security

We constantly review our procedures to make sure data is secure. Data is stored on encrypted hard drives and never stored for a period that is longer than necessary. No digital photos are stored with any identifying information alongside such as names or addresses.

All individuals who are the subject of personal data held by us 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.

• How Solent Photography Ltd remove the personal data 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 to solentphoto@aol.com with the subject as ‘GDPR’.

The Data Controller will aim to provide the relevant data within 28 days.

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

      V.       Disclosing data for other reasons

In certain circumstances, the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Solent Photography Ltd will disclose the requested data. However, we will ensure the request is legitimate, seeking assistance from legal advisers where necessary.

     VI.       Photographers

Martin Carroll is the sole photographer of Solent Photography Ltd and is fully DBS checked which is kept up to date using the DBS Update Service. He carries company and private ID displaying DBS number and where it can be checked as well as the full original DBS certificate.