Privacy Policy

Introduction

 In its everyday business operations The Plytek Group makes use of a variety of data about identifiable individuals, including data about:

  • Current, past and prospective employees
  • Customers
  • Other stakeholders

In collecting and using this data, the organisation is subject to a variety of legislation controlling how such activities may be carried out and the safeguards that must be put in place to protect it.

The Plytek Group is committed to preserving the privacy of its customers and employees and to complying with relevant GDPR legislation.

We have a Data Protection regime in place to oversee the effective and secure processing of your personal data. We shall not disclose the information you entrust us with to third parties except where we have a statutory or contractual duty to do so (including to your employer, if sponsored), where you have given prior approval or where an official third-party data processing agreement exists.

The purpose of this policy is to set out the relevant legislation and to describe the steps The Plytek Group is taking to ensure that it complies with it.

This control applies to all systems, people and processes that constitute the organisation’s information systems, including board members, directors, employees, suppliers and other third parties who have access to The Plytek Group’s systems.

The following policies and procedures are relevant to this document:

  • Data Protection Impact Assessment Process
  • Information Security Incident Response Procedure
  • GDPR Roles, Responsibilities and Authorities
  • Records Retention and Protection Policy

 

The General Data Protection Regulation

 The General Data Protection Regulation 2016 (GDPR) is one of the most significant pieces of legislation affecting the way that The Plytek Group carries out its information processing activities. Significant fines are applicable if a breach is deemed to have occurred under the GDPR, which is designed to protect the personal data of citizens of the European Union. It is The Plytek Group’s policy to ensure that our compliance with the GDPR and other relevant legislation is clear and demonstrable at all times.


The Plytek Group must ensure that it complies with all applicable sections of the GDPR principles both in the processing it currently carries out and as part of the introduction of new methods of processing such as new IT systems.

Rights of the Individual

The data subject also has rights under the GDPR. These consist of:

 

              1.        The right to be informed

              2.        The right of access

              3.        The right to rectification

              4.        The right to erasure

              5.        The right to restrict processing

              6.        The right to data portability

              7.        The right to object

              8.        Rights in relation to automated decision making and profiling.

 

Each of these rights must be supported by appropriate procedures within The Plytek Group that allow the required action to be taken within the timescales stated in the GDPR.

These timescales are shown in Table 1.

Data Subject Request

Timescale

The right to be informed

When data is collected

The right of access

One month

The right to rectification

One month

The right to erasure

Without undue delay

The right to restrict processing

Without undue delay

The right to data portability

One month

The right to object

On receipt of objection

Rights in relation to automated decision making and profiling.

Not specified


We’ll keep your personal data for at least 7 years and for 10 years where HSE requirements are involved.

Consent

 Unless it is necessary for a reason allowable in the GDPR, explicit consent is obtained from a data subject to collect and process their data. Transparent information about our usage of their personal data is provided to data subjects at the time that consent is obtained and their rights with regard to their data explained, such as the right to withdraw consent. This information must be provided in an accessible form, written in clear language and free of charge.

If the personal data is not obtained directly from the data subject, then this information must be provided within a reasonable period after the data are obtained and definitely within one month.

Privacy by Design

The Plytek Group has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect, or process personal data will be subject to due consideration of privacy issues, including the completion of one or more data protection impact assessments.

The data protection impact assessment will include.

  • Consideration of how personal data will be processed and for what purposes
  • Assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s)
  • Assessment of the risks to individuals in processing the personal data
  • What controls are necessary to address the identified risks and demonstrate compliance with legislation

Use of techniques such as data minimisation and pseudonymisation should be considered where applicable and appropriate.

Transfer of Personal Data

Transfers of personal data outside the European Union will not occur by The Plytek Group
 

Breach Notification

It’s The Plytek Group’s policy to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. In line with the GDPR, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant Data Protection Authority (DPA) will be informed within 72 hours. This will be managed in accordance with our Information Security Incident Response Procedure which sets out the overall process of handling information security incidents.

Addressing Compliance to the GDPR

 The following actions are undertaken to ensure that The Plytek Group complies at all times with the accountability principle of the GDPR:

  • The legal basis for processing personal data is clear and unambiguous
  • Dawn Torr is appointed with specific responsibility for data protection in the organisation
  • All staff involved in handling personal data understand their responsibilities for following good data protection practice
  • Training in data protection has been provided to all staff
  • Rules regarding consent are followed
  • Routes are available to data subjects wishing to exercise their rights regarding personal data and such enquiries are handled effectively
  • Regular audits of procedures involving personal data are carried out through our management system
  • Privacy by design is adopted for all new or changed systems and processes
  • The following documentation of processing activities is recorded;

o   Organisation/learner name and relevant details

o   Purposes of the personal data processing

o   Categories of individuals and personal data processed

o   Categories of personal data recipients

o   Personal data retention schedules

o   Relevant technical and organisational controls in place

These actions will be reviewed on a regular basis as part of the management review process of the information security management system.

Contact us:

Any comments, questions or suggestions about this privacy policy or our handling of your personal data should be emailed to carole.burley-marsh@plytekservices.net

Alternatively, you can contact us at our head quarters, using the following postal address or telephone numbers:

Carole Burley-Marsh, Plytek Group, Plytek House, Walkers Site, Ollerton Road, Tuxford, Newark, NG22 0PQ   Tel: 01302 378 882