This Policy sets out the obligations of www.amaze3d.co.uk (“the Company”) with regard to data protection and the rights of website users, customers, business contacts etc. (“data subjects”) in respect of their personal data under the Data Protection Act 1998 (“the Act”). Under the Act, “personal data” is defined as data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller (the Company in this context), and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.
This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
The Company is committed not only to the letter of the law but also to the spirit of the law and places a high premium on the correct, lawful and fair handling of all personal data, respecting the legal rights, privacy and trust of all individuals with whom it deals.
The Company is registered with the Information Commissioner as a data controller under the register held by the Information Commissioner pursuant to Section 19 of the Act.
2. The Data Protection Principles
This Policy aims to ensure compliance with the Act. The Act sets out eight principles with which any party handling personal data must comply. All personal data:
2.1 Must be processed fairly and lawfully, meaning that at least one of the following conditions must be met:
2.1.1 The data subject has given his or her consent to the processing;
2.1.2 The processing is necessary for the performance of a contract to which the data subject is a party, or for the taking of steps at the request of the data subject with a view to entering into a contract;
2.1.3 The processing is necessary for compliance with any legal obligation to which the data controller is subject, other than an obligation imposed by contract;
2.1.4 The processing is necessary in order to protect the vital interests of the data subject;
2.1.5 The processing is necessary for the administration of justice, for the exercise of any functions of either House of Parliament, for the exercise of any functions conferred on any person by or under any enactment, for the exercise of any functions of the Crown, a Minister of the Crown or a government department, or for the exercise of any other functions of a public nature exercised in the public interest by any person;
2.1.6 The processing is necessary for the purposes of legitimate interests pursued by the data controller or by the third party or parties to whom the data is disclosed, except where the processing is unwarranted in any particular case by reason of prejudice to the rights and freedoms or legitimate interests of the data subject.
2.2 Must be obtained only for specified and lawful purposes and shall not be processed in any manner which is incompatible with those purposes;
2.3 Must be adequate, relevant and not excessive with respect to the purposes for which it is processed;
2.4 Must be accurate and, where appropriate, kept up to date;
2.5 Must be kept for no longer than is necessary in light of the purpose(s) for which it is processed;
2.6 Must be processed in accordance with the rights of data subjects under the Act (for which, see Part 3 of this Policy);
2.7 Must be protected against unauthorised or unlawful processing, accidental loss, destruction or damage through appropriate technical and organisational measures; and
2.8 Must not be transferred to a country or territory outside of the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
3. Rights of Data Subjects
Under the Act, data subjects have the following rights:
o The right to access a copy of their personal data held by the Company by means of a Subject Access Request (for which, see Part 8 of this Policy);
o The right to object to any processing of his or her personal data that is likely to cause (or that is causing) damage or distress. Data subjects should make any such objection in writing to firstname.lastname@example.org and the Company shall respond within 21 days either notifying the data subject of its compliance, or explaining why the Company feels that any aspect of the data subject’s request is unjustified;
o The right to prevent processing for direct marketing purposes;
o The right to object to decisions being taken by automated means (where such decisions will have a significant effect on the data subject) and to be informed when any such decision is taken (in which case the data subject has the right to require the data controller (by written notice) to reconsider the decision;
o The right to have inaccurate personal data rectified, blocked, erased or destroyed in certain circumstances;
o The right to claim compensation for damage caused by the Company’s breach of the Act.
4. Personal Data
Personal data is defined by the Act as data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.
The Act also defines “sensitive personal data” as personal data relating to the racial or ethnic origin of the data subject; their political opinions; their religious (or similar) beliefs; trade union membership; their physical or mental health condition; their sexual life; the commission or alleged commission by them of any offence; or any proceedings for any offence committed or alleged to have been committed by them, the disposal of such proceedings or the sentence of any court in such proceedings.
The Company only holds personal data that is directly relevant to its dealings with a given data subject. That data will be collected, held, and processed in accordance with the data protection principles and with this Policy.
5. Processing Personal Data
Any and all personal data collected by the Company (as detailed in Part 4 of this Policy) is collected in order to ensure that the Company can provide the best possible service to its customers, and can work effectively with its partners, associates and affiliates and efficiently manage its employees, contractors, agents and consultants. The Company may also use personal data in meeting certain obligations imposed by law.
Certain data collected by the Company, such as IP addresses, certain information gathered by cookies, pseudonyms and other non-identifying information will nonetheless be collected, held and processed to the same standards as personal data.
Personal data may be disclosed within the Company, provided such disclosure complies with this Policy. Personal data may be passed from one department to another in accordance with the data protection principles and this Policy. Under no circumstances will personal data be passed to any department or any individual within the Company that does not reasonably require access to that personal data with respect to the purpose(s) for which it was collected and is being processed.
In particular, the Company shall ensure that:
o All personal data collected and processed for and on behalf of the Company by any party is collected and processed fairly and lawfully;
o Data subjects are always made fully aware of the reasons for the collection of personal data and are given details of the purpose(s) for which the data will be used;
o Personal data is only collected to the extent that is necessary to fulfil the purpose(s) for which it is required;
o All personal data is accurate at the time of collection and kept accurate and up to date while it is being held and/or processed;
o No personal data is held for any longer than necessary in light of the purpose(s) for which it is required;
o Whenever cookies or similar technologies are used online by the Company, they shall be used strictly in accordance with the requirements of the Privacy and Electronic Communications Regulations, providing full details of cookie use and guidance on privacy;
o Individuals are provided with a simple, accessible method of amending any data submitted by them online;
o Individuals are informed if any data submitted by them online cannot be fully deleted at their request under normal circumstances (for example, because a file uploaded by a user has been backed up) and how to request that the Company deletes any other copies of that data, where it is within the individual’s right to do so;
o All personal data is held in a safe and secure manner, as detailed in Part 6 of this Policy, taking all appropriate technical and organisational measures to protect the data;
o No personal data is transferred outside of the European Economic Area (as appropriate) without first ensuring that the destination country offers adequate levels of protection for personal data and the rights of data subjects; and
o All data subjects can fully exercise their rights with ease and without hindrance.
6. Access by Data Subjects
A data subject may make a subject access request (“SAR”) at any time to find out more about the information which the Company holds about them.
o SARs should be made in writing, addressed to email@example.com ,
o SARs must make it clear whether it is the data subject themselves that is making the request or whether it is a person acting on his or her behalf. In either case, proof of identity must be provided. If the SAR is made on another’s behalf, the individual making the request must provide clear evidence of their authorised capacity to act on behalf of the data subject.
o The Company currently requires a fee of £10 (the legal maximum) for each SAR
Upon receipt of a SAR the Company shall have a maximum period of 40 calendar days within which to respond fully, but shall always aim to acknowledge receipt of SARs within 21. The following information will be provided to the data subject:
o Whether or not the Company holds any personal data on the data subject;
o A description of any personal data held on the data subject;
o Details of what that personal data is used for;
o Details of how to access that personal data and how to keep it up to date;
o Details of any third-party organisations that personal data is passed to; and
o Details of any technical terminology or codes.
7. Notification to the Information Commissioner’s Office
As a data controller, the Company is not required to notify the Information Commissioner’s Office that it is processing personal data. are under no requirement to register organisations that do not decide how personal data is processed are exempt, we therefore do not have to register with the ICO.
However, it is important that www.amaze3d.co.uk adheres to the principles of the Data Protection Act (DPA) and we understand best practice for managing information. Implementation of Policy
This Policy has been approved & authorised by:
Name: Jon Mayers
Due for Review by: 01.01.2018