Privacy Policy

SP 30yr AUS

Introduction

Scottish Pacific 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 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

The data protection policy ensures that Scottish Pacific:

  • Complies with data protection law and follows good practice
  • Protects the rights of staff, customers and commercial partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach

 

Data Protection Law

The Data Protection Act 1998 describes how organisations – including Scottish Pacific – 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 Data Protection Act is underpinned by eight important principles. These say that personal data must:

  1. Be processed fairly and lawfully
  2. Be obtained only for specific, lawful purposes
  3. Be adequate, relevant and not excessive
  4. Be accurate and kept up to date
  5. Not be held for any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. Not be transferred outside of the European Economic Area, unless that country or territory also ensures an adequate level of protection.

 

People, Risks and Responsibilities

 Policy Scope

This policy applies to:

  • The Head Office of Scottish Pacific Business Finance
  • The UK branch of Scottish Pacific Business Finance
  • All staff and volunteers working on work related to the European Economic Area
  • All contractors, suppliers and other people working on behalf of Scottish Pacific in the European Economic Area

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

  • Names of Individuals
  • Postal Addresses
  • Email Addresses
  • Telephone Numbers
  • Any other kind of information relating to individuals.

 

Data Protection Risks

This policy helps to protect Scottish Pacific from some very real data security risks, including:

  • Breaches of Confidentiality. For example, information being given out inappropriately to an unauthorised party.
  • Failing to offer Choice. For example 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 date.

 

Responsibilities

Everyone who works for or with Scottish Pacific within the European Economic Area has some responsibility for ensuring that 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, the following people have key areas of responsibility.

  • The Scottish Pacific Board is ultimately responsible for ensuring that the business meets its legal obligations.
  • The Data Protection Officer, Steven Pleace, 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. This is to be every 12 months.
    • 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 Scottish Pacific holds about them. (these are known as ‘subject access requests’)
    • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
  • The Head of IT & Business Systems, Nick McAvoy, is responsible for:
    • Ensuring that 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 computer services.
  • The Chief Customer Officer, Ben Cutler, 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.
  • Scottish Pacific 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.
  • 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 to ensure that the information contained within it is not 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.

 

Data Storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to  or risk&

Paper Storage

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 or placed into a confidential waste bin and disposed of securely when no longer required.

 

Electronic Storage

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 USB stick or portable hard drive), 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 drives approved by the business.
  • 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 Scottish Pacific standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like smartphones or tablets.
  • All servers and computers containing data should be protected by approved security software and firewalls.

 

Data Use

Personal data is of no value to Scottish Pacific 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 normally be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • Personal data should not be transferred out of the European Economic Area unless sent to an authorised representative of Scottish Pacific in Australia.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

 

Data Accuracy

The law requires Scottish Pacific 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 Scottish Pacific 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 should be held in as few places as necessary. Staff should not create any unrequired additional data sets.
  • Staff should take every opportunity to ensure data is updated. For example when completing a facility review.
  • Scottish Pacific will make it easy for data subjects to update the information Scottish Pacific holds about them. For instance through an email request to their Client Relationship Manager.
  • Data should be updated as inaccuracies are discovered. For instance, if a guarantor can no longer be reached on their stored telephone number, it should be removed from the database.
  • It is the responsibility of the Chief Customer Officer to ensure that marketing databases are checked against industry suppression files every six to twelve months.

 

Subject Access Requests

All individuals who are the subject of personal data held by Scottish Pacific are entitled to:

  • Ask what information the company holds about them and why.
  • Ask how to gain access to this information.
  • Be informed of how to keep this information up to date.
  • Be informed how the company is meeting its data protection obligations.

If any individual contacts the company requesting any of the above information, this is called a subject access request.

Subject access requests from individual should be made by email addressed to the Data Protection Officer for Scottish Pacific at ().

Individuals will be charged £10 per subject access request. The Data Protection Officer will aim to provide the relevant data within 14 days.

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

 

Disclosing Data for Other Reasons

Scottish Pacific aims to ensure that individuals are aware that their data is being processed, and that they understand:

  • How data pertaining to them 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.

This is available on request. A version of this is also available on the company website.

 

Additional Reading On The Act

Further reading and links to information regarding the Data Protection Act 1998 can be found at the following location:

https://www.gov.uk/data-protection

 

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