We are committed to safeguarding the privacy of our website visitors nad customers. This policy sets out how we will treat your personal information.
What information do we collect?
- Information about your computer and about your visits to and use of this website, such as your IP address, geographical location, browser type, referral source, length of visit and number of page views.
- Information relating to any transactions carried out between you and us on or in relation to this website, including information relating to any purchases you make of our goods or services.
- Information that you provide to us for the purpose of registering with us.
- Information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters.
- Any other information that you choose to send to us.
We may collect, store and use the following kinds of personal data:
USING YOUR PERSONAL DATA:
- Administer the website.
- Improve your browsing experience by personalising the website.
- Enable your use of the services available on the website.
- Send to you goods purchased via the website, and supply to you services purchased via the website.
- Send statements and invoices to you, and collect payments from you.
- Send you general (non-marketing) commercial communications.
- Send you email notifications which you have specifically requested.
- Send to you our newsletter and other marketing communications (relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you) by post or, where you have specifically agreed to this, by email or similar technology. You can inform us at any time if you no longer require marketing communications to be sent by emailing us.
- Provide third parties with statistical information about our users – but this information will not be used to identify any individual user.
- Deal with enquiries and complaints made by or about you relating to the website.
GDPR COMPLIANCE AMENDMENT:
Ministry of Furniture Ltd needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact. This amendement to the 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.
Why this policy exists
This data protection policy ensures Ministry of Furniture Ltd:
- Complies with data protection law and follow good practice
- 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
Data protection law
The General Data Protection Regulation (GDPR) (EU) 2016/679 describes how organisations — including Ministry of Furniture 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.
The GDPR is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
This policy applies to:
- The head office of Ministry of Furniture Ltd
- All branches of Ministry of Furniture Ltd
- All staff and volunteers of Ministry of Furniture Ltd
- All contractors, suppliers and other people working on behalf of Ministry of Furniture 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 (GDPR) (EU) 2016/679. 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 Ministry of Furniture Ltd 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 the company uses data relating to them.
- Reputational damage For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with Ministry of Furniture Ltd has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure 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 Ministry of Furniture Ltd meets its legal obligations.
- The Management Reporting and Data Specialist, Gary Shiels, 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 staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data Ministry of Furniture Ltd holds about them (also called ‘subject access requests’).
- Checking and approving any contracts or agreements with third parties that may handle the company’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 the company is considering using to store or process data. For instance, cloud computing services.
- The Marketing Executive, Brian Fitzgerald, is responsible for:
- 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 other staff to ensure marketing initiatives abide by data protection principles.
General staff guidelines
- The only people able to access data covered by this policy should be those who need it for their work.
- Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
- Ministry of Furniture Ltd will provide training to all employees to help them understand their responsibilities when handling data.
- Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
- In particular, strong passwords must be used and they should never be shared.
- Personal data should not be disclosed to unauthorised people, either within the company or externally.
- Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
- Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
When data is stored on paper, it should be 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 should be kept in a locked drawer or filing cabinet.
- Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
- Data printouts should be 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 should be 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), these should be kept locked away securely when not being used.
- Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
- Servers containing personal data should be sited in a secure location, away from general office space.
- Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
- Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Ministry of Furniture 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:
- When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
- Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
- Personal data should never be transferred outside of the European Economic Area.
- Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires Ministry of Furniture 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 Ministry of Furniture Ltd should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
- Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
- Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
- Ministry of Furniture Ltd will make it easy for data subjects to update the information Ministry of Furniture Ltd holds about them. For instance, via the company website.
- Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on
their stored telephone number, it should be removed from the database.
- It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject access requests
All individuals who are the subject of personal data held by Ministry of Furniture Ltd 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
- 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, addressed to the data controller at firstname.lastname@example.org
The data controller may supply a standard request form, although individuals do not have to use this.
Ministry of Furniture Ltd will offer this service free of charge but reserve the right to charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive, or for further copies of the same information that has previously been provided. This fee will be based on the fee of the administrative cost of providing the information.
The data controller 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, GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Ministry of Furniture Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Ministry of Furniture Ltd 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, the company has a privacy statement, setting out how data relating to individuals is used by the company.
- To the extent that we are required to do so by law.
- In connection with any legal proceedings or prospective legal proceedings.
- In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
- To the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling.
INTERNATIONAL DATA TRANSFERS
SECURITY OF YOUR PERSONAL DATA
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. You are responsible for keeping your password and user details confidential. We will not ask you for your password.
You may instruct us to provide you with any personal information we hold about you. Provision of such information may be subject to the payment of a fee (currently fixed at £50.00). You may instruct us not to process your personal data for marketing purposes by email at any time. (In practice, you will usually either expressly agree in advance to our use of your personal data for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal data for marketing purposes.)
THIRD PARTY WEBSITES
The website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites.
Please let us know if the personal information which we hold about you needs to be corrected or updated.