People Puzzles GDPR Policy

Introduction

Purpose

The organisation is committed to being transparent about how it collects and uses personal data. This policy sets out the organisation’s commitment to data protection, and individual rights and obligations in relation to personal data.

This statement describes how personal data must be collected, handled and stored to meet People Puzzles data protection standards.

Definitions

“Personal data” is any information that relates to an 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 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

The organisation processes HR-related personal data in accordance with the following data protection principles:

The organisation processes personal data lawfully, fairly and in a transparent manner.
The organisation collects personal data only for specified, explicit and legitimate purposes.
The organisation processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
The organisation keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
The organisation keeps personal data only for the period necessary for processing.
The organisation adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

Individual rights

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

Subject access requests

To make a subject access request, the individual should send the request to [email protected]. In some cases, the organisation may need to ask for proof of identification before the request can be processed. The organisation will inform the individual if it needs to verify his/her identity and the documents it requires.
The organisation 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.
The organisation will normally respond to a request within a period of one month from the date it is received. In some cases, such as where the organisation processes large amounts of the individual’s data, it may respond within three months of the date the request is received. The organisation 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, the organisation is not obliged to comply with it. Alternatively, the organisation 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 the organisation has already responded. If an individual submits a request that is unfounded or excessive, the organisation will notify him/her that this is the case and whether or not it will respond to it.

Other rights

Individuals have a number of other rights in relation to their personal data. They can require the organisation 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 the organisation 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 whether or not the individual’s interests override the organisation’s legitimate grounds for processing data.

To ask the organisation to take any of these steps, the individual should send the request to [email protected].

Data security

The organisation takes the security of personal data seriously. The organisation 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.

The organisation’s IT Security and Data policy is available upon request.

The organisation’s Marketing and Data Policy is available upon request.

Where the organisation 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. The organisation’s third party/supplier data policies are available upon request.

Impact assessments

Some of the processing that the organisation carries out may result in risks to privacy. Where processing would result in a high risk to individual’s rights and freedoms, the organisation will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

Data breaches

If the organisation discovers that there has been a breach of 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. The organisation will record all data breaches regardless of their effect.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell 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

Personal data may be transferred to countries outside the EE using carefully selected suppliers and providers to perform other discreet tasks which may result in data being transferred outside the EEA.

Updated 22.05.18