Magna Connections Data Protection Policy
This policy sets out how we seek to protect personal data and ensure that staff understand the rules governing their use of personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.
The purposes for which personal data is used by us:
Personnel, administrative, financial, regulatory, payroll and business development purposes.
Business purposes include the following:
- Compliance with our legal, regulatory and corporate governance obligations and good practice
- Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
- Ensuring business policies are adhered to (such as policies covering email and internet use)
- Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking
- Investigating complaints
- Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments
- Monitoring staff conduct, disciplinary matters
- Marketing our business
- Improving services
Information relating to identifiable individuals, such as job applicants, current and former employees, agency, contract and other staff, clients, suppliers and marketing contacts.
Personal data we gather may include: individuals' contact details, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.
Sensitive personal data
Personal data about an individual's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings—any use of sensitive personal data is strictly controlled in accordance with this policy.
Who is responsible for this policy?
Fair and lawful processing
We process personal data fairly and lawfully in accordance with individuals’ rights. This generally means that we do not process personal data unless the individual whose details we are processing has consented to this happening.
The Data Protection Officer’s responsibilities:
· Keeping the board updated about data protection responsibilities, risks and issues
· Reviewing all data protection procedures and policies on a regular basis
· Arranging data protection training and advice for all staff members and those included in this policy
· Answering questions on data protection from staff, board members and other stakeholders
· Responding to individuals such as clients and employees who wish to know which data is being held on them by Magna Connections Ltd
· Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing
Responsibilities of the IT Manager
· Ensure all systems, services, software and equipment meet acceptable security standards
· Checking and scanning security hardware and software regularly to ensure it is functioning properly
· Researching third-party services, such as cloud services the company is considering using to store or process data
Responsibilities of the Marketing Manager
· Approving data protection statements attached to emails and other marketing copy
· Addressing data protection queries from clients, target audiences or media outlets
· Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy
· In most cases this provision will apply to routine business data processing activities.
Our Terms of Business contains a Privacy Notice to clients on data protection.
Sensitive personal data
In most cases where we process sensitive personal data we will require the data subject's explicit consent to do this unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.
Accuracy and relevance
We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO, Natalia Dawid.
Your personal data
You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required. For example, if your personal circumstances change, please inform the Data Protection Officer so that they can update your records.
We keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third party organisations.
Storing data securely
· In cases when data is stored on printed paper, it is kept in a secure place where unauthorised personnel cannot access it
· Printed data is shredded when it is no longer needed
· Data stored on a computer is protected by strong passwords that are changed regularly. We encourage all staff to use a password manager to create and store their passwords.
· Data stored on CDs or memory sticks is locked away securely when they are not being used
· The DPO approves any cloud used to store data
· Servers containing personal data is kept in a secure location, away from general office space
· Data is regularly backed up in line with the company’s backup procedures
· Data is never saved directly to mobile devices such as laptops, tablets or smartphones
· All servers containing sensitive data are approved and protected by security software and strong firewall.
Transferring data internationally
Subject access requests
Please contact the Data Protection Officer if you would like to correct or request information that we hold about you. There are also restrictions on the information to which you are entitled under applicable law.
Processing data in accordance with the individual's rights
All staff will receive training on this policy. New joiners will receive training as part of the induction process. Further training will be provided at least every two years or whenever there is a substantial change in the law or our policy and procedure.
Where not specified previously in this policy, the following provisions will be in effect on or before 25 May 2018.
Privacy Notice - transparency of data protection
Being transparent and providing accessible information to individuals about how we will use their personal data is important for our organisation. The following are details on how we collect data and what we will do with it:
Who is collecting it?
Magna Connections Ltd
What information why and how is it collected?
1.When you complete a registration form
2.When you supply us with Curriculum Vitae
3.When you supply us with any other information (verbally or in writing) at any stage of you being listed with Magna Connections as a candidate
4.When we receive any reference about you
5.When we obtain feedback from inquires we may make with your former employer, work colleagues, professional associations or any applicable registration body
6.When we receive feedback on your performance (regardless of whether this is positive or negative)
7.When we receive notification of any complaint about you or workplace accident that you have been involved in
8. When we receive an application from you in response to a job placement advertisement
9.When we obtain any information about investigation, inquest, inquiry, litigation or prosecution that you are involved in.
How will it be used and who will it be shared with?
Upon receiving authorisation on collection of your personal information by the abovenamed means you authorise Magna Connections Ltd to use your information in connections with the following:
Your suitability for employment/or placement
Assessment of your performance and prospects
Payment for work you may have completed
Follow up referrals for further work
Checking for work availability
Any tests or assessments you may be required to undergo i.e. Medical tests
Any insurance claim or inquiry that requires disclosure of your personal information
Our handling of any complaint, investigation or inquiry of which you are or have been involved in.
Disclosure of Personal Information to Third Parties:
Any information supplied to a client by Magna Connections Ltd regarding a candidate is done so on a strictly confidential bases for payroll purposes and to enable the client to assess a candidate’s suitability for the position and except where authorised or required by law shall not be disclosed to any third party without the candidate’s consent.
Identity and contact details of the data controller
Natalia Dawid 07940 526 502
Candidates CV and personal details will be stored on Magna Connections shared drive no longer than 2 years from day of receiving CV
Candidates CV, personal details and registration documents in paper form will be stored in locked unit for a period of 5 years.
After these periods of time candidate details will be deleted from our system, hard copies of CV’s, registration forms, personal and financial details will be securely shredded.
Conditions for processing
We will ensure any use of personal data is justified using at least one of the conditions for processing and this will be specifically documented. All staff who are responsible for processing personal data will be aware of the conditions for processing. The conditions for processing will be available to data subjects in the form of a privacy notice.
Justification for personal data
We will process personal data in compliance with all six data protection principles.
We will document the additional justification for the processing of sensitive data, and will ensure any biometric and genetic data is considered sensitive.
The data that we collect is subject to active consent by the data subject. This consent can be revoked at any time.
Criminal record checks
Any criminal record checks are justified by law. Criminal record checks cannot be undertaken based solely on the consent of the subject.
Upon request, a data subject should have the right to receive a copy of their data in a structured format. These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system.
Right to be forgotten
A data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.
Privacy by design and default
Privacy by design is an approach to projects that promote privacy and data protection compliance from the start. The DPO will be responsible for conducting Privacy Impact Assessments and ensuring that all IT projects commence with a privacy plan.
When relevant, and when it does not have a negative impact on the data subject, privacy settings will be set to the most private by default.
International data transfers
No data may be transferred outside of the EEA without first discussing it with the data protection officer. Specific consent from the data subject must be obtained prior to transferring their data outside the EEA.
Data audit and register
Regular data audits to manage and mitigate risks will inform the data register. This contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant.
By providing personal information to us, whether verbally or in writing by whether means then you expressly acknowledge that you have read and understood the terms and conditions outlined under our Privacy statement and as a result of this you consent to Magna Connections collecting personal information about you and disclosing and using that information as set out in the above terms.
If you wish to access your information or request a correction you should contact us at Office@magnaconnections.co.uk
Consequences of failing to comply
The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in dismissal. A solicitor in breach of Data Protection responsibility under the law or the Code of Conduct may be struck off.
If you have any questions or concerns about anything in this policy, do not hesitate to contact the DPO.