Data Protection and Data Security Policy
Statement of policy and purpose of policy
- Corrugated Containers Ireland Ltd (CCI) is committed to ensuring that all personal information handled by us will be processed accordingly to legally compliant standards of data protection and data security.
- The purpose is of this policy is to help us achieve our data protection and data security aims by:
- Notifying our staff of the types of personal information that we may hold about them and what we do with that information;
- Ensuring staff understand our rules and the legal standards for handling personal information relating to staff and others: and
- Clarifying the responsibilities and duties of staff in respect of data protection and data security.
- This is a statement of policy only and does not form part of your contract of employment. We may amend this policy at any time, in our absolute discretion.
Who is responsible for data protection and data security?
- Maintaining appropriate standards of data protection and data security is a collective task shared between us and you. This policy and the rules contained in it apply to all staff of the Employer, irrespective of seniority, tenure and working hours, including all employees, directors, consultants, contractors, casual or agency staff, fixed term staff & any volunteers (Staff).
- The board of directors has overall responsibility for ensuring that all personal information is handled in compliance with the law and has appointed the Office Manager as the Data Protection Officer with responsibility for data processing and data security.
- All Staff have personal responsibility to ensure compliance with this policy, to handle all personal information consistently with the principles set out here and to ensure that measures are taken to protect that data security. Managers have special responsibility for leading by example and monitoring and enforcing compliance.
- Any breach of this policy will be taken seriously and may result in disciplinary action.
What personal information and activities are covered by this policy?
- This policy covers personal info;
- Which relates to a living individual who can be identified either from that information in isolation or by reading it together with other information we possess;
- Is stored electronically or on paper in a filing system;
- In the form of statements of opinion as well as facts;
- Which relates to Staff (present past or future) or to any other individual whose personal info we handle or control;
- Which we obtain, hold or store, organise, disclose or transfer, amend, retrieve, use handle, process, transport or destroy.
What personal information do we process about Staff and what do we do with it?
- We collect personal info about you which;
- You provide, or we gather before or during your employment or engagement with us;
- Is provided by third parties, such as references or information from suppliers or another party that we do business with; or
- Is in the public domain.
- The types of personal information that we may collect, store and use about you include records relating to your;
- Home address and contact details as well as contact details for your next of kin
- Recruitment (including your application form or cv, any references received and details of your qualifications);
- Pay records, national insurance number details of your taxes and employment benefits such as pension and health insurance (including details of any claims made);
- Any sickness absence or medical information provided;
- Sexual orientation, where this is disclosed to us (e.g. through providing details of your spouse or partner for the administration of benefits);
- Telephone, email, internet, fax, or instant messenger use;
- Performance and any disciplinary matters, grievances, complaints, or concerns in which you are involved.
- We will use information to carry out our business, to administer your employment or engagement and to deal with any problems or concerns you may have including;
- Staff Contact List: to compile and circulate list of contact details to contact you outside working hours
- Sickness records: to maintain a record of your sickness absence and copies of doctor’s notes or other documents supplied to us in connection with your health, to inform your colleagues and others that you are absent through sickness, as reasonably necessary to manage your absence, to deal with unacceptably high or suspicious sickness absence, or to inform reviewers for appraisal purposes of our sickness absence level.
- Monitoring IT systems: to monitor your use of emails, internet telephone and fax, computer or other communications or IT resources.
- Disciplinary, grievance, or legal matters: in connection with any disciplinary, grievance, legal, regulatory or compliance matters or proceedings that may involve you.
- Performance Reviews: to carry out performance reviews.
- We confirm that for the purposes of the GDPR, CCI is the Data Controller of the personal information in connection with your employment. This means that we determine the purposes for which, and the way, your personal information is processed.
- If you consider that any info held about you is inaccurate then you should tell your line manager, and, if we agree that the information is inaccurate then we will correct it. If we do not agree with the correction, then we will note your comments.
- We will take reasonable steps to ensure that your personal info is kept secure, as described later in this policy and in general, we will not disclose your personal information to others outside your employment. However, we may need to disclose personal info about Staff:
- For the administration of your employment and associated benefits e.g. to the providers of our pension or insurance schemes; or
- To comply with our legal obligations or assist in a criminal investigation or to seek legal or professional advice in relation to employment issues, which may involve disclosure to our lawyers, accountants or auditors and to legal and regulatory authorities, such as HM Revenue and Customs;
- To other parties which provide products or services to us.
- By providing your personal information to us, you consent to the use of your personal information (including any sensitive personal data) in accordance with this policy
Data Protection Principle
- Staff whose work involves using personal data relating to Staff or others must comply with this policy and with the eight legal data protection principles which require that personal information is:
- Processed fairly and lawfully: We must always have a lawful basis to process personal information. In most (but not all) cases, the person to whom the information relates (the subject) must have given consent. The Subject must be told who controls the information (us), the purpose(s) for which we are processing the information and to whom it may be disclosed.
- Processed for limited purposes and in an appropriate way. Personal information must not be collected for one purpose and then used for another. If we want to change the way we use personal information we must first tell the Subject.
- Adequate, relevant and not excessive for the purpose.
- Regular checks must be made to correct or destroy inaccurate information.
- Not kept longer than necessary for the purpose. Information must be destroyed or deleted when we no longer need it. For guidance on how long particular information should be kept, contact the Data Protection Officer.
- Processed in line with Subject’s rights. Subjects have a right to request access to their personal information, request the correction of inaccurate data and to prevent their personal info being used in a way likely to cause them or another person damage or distress.
- See further about data security below.
- Not transferred to people or organisations situated in countries without adequate protection.
- Some personal information needs even more careful handling. This includes about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life or about criminal offences. Strict conditions apply to processing this sensitive personal information and the Subject must normally have given specific and express consent to each way in which the information is used.
- We must all protect personal information in our possession from being accessed, lost, deleted or damaged unlawfully or without proper authorisation using data security measures.
- Maintaining data security means making sure that;
- Only people who are authorised to use the info can access it;
- Information is accurate and suitable for the purpose for which it is processed; and
- Authorised persons can access info if they need it for authorised purposes. Personal info therefore should not be stored on individual computers but instead on our central system.
- By law, we must use procedures and technology to secure personal information throughout the period that we hold or control it, from obtaining to destroying the information.
- Personal info must not be transferred to any person to process (e.g. while performing services for us on or our behalf), unless that person has either agreed to comply with our data security procedures or we are satisfied that other adequate measures exist.
- Security procedures include:
- Physically securing information. Any desk or cupboard containing confidential info must be kept locked. Computers should be locked with password or shut down when they are left unattended and discretion should be used when viewing personal info on a monitor to ensure that is not visible to others.
- Controlling access to premises: Staff should report to security if they see any person they do not recognise in an entry-controlled area.
- Telephone Precautions; care must be taken by Staff who deal with telephone enquiries to avoid in inappropriate disclosures. In particular;
- The identity of any telephone caller must be verified before personal info is disclosed.
- If the caller’s identity cannot be verified satisfactorily then they should be asked to put their query in writing:
- Do not allow callers to bully you into disclosing information. In case of problems or uncertainty, contact the Data Protection Officer.
- Methods of disposal. Copies of personal information, whether on paper or on any physical storage device, must be physically destroyed when they are no longer needed. Paper documents should be shredded and CDs or memory sticks or similar must be rendered permanent.
- As an employer, it is our duty to notify the DPC of any data security breach within 72hours of becoming aware of the breach, unless the risk to rights and freedoms of data subjects is unlikely.
- By law, any Subject (including Staff) may make a formal request for information that we hold about them, provided that certain conditions are met. The request must be made in writing & responded to within 1 month of receipt of request. Documents will be provided free of charge unless the request is ‘manifestly unfounded or excessive’ in which case a reasonable fee may be charged. Guidance on the circumstances in which a fee may be so charged, and the level of the fee which may be charged is awaited.
As an Employer, we are also obliged to provide further information to staff that make data access requests: This includes:
- Purposes of processing
- Categories of personal data concerned
- To whom the personal data has been or will be disclosed
- Whether the data will be or has been transferred outside the EU.
- The period for which that data will be stored
- The right to make a complaint to the DPC.
- The right to make a request deletion of the personal data
- Whether the data has been subject to automated decision making.