Clock House Farm is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out the company’s commitment to data protection, and individual rights and obligations in relation to personal data.
This policy applies to the personal data of job applicants, employees [workers, contractors, volunteers, interns, apprentices] and former employees, referred to as HR-related personal data. This policy does not apply to the personal data of clients or other personal data processed for business purposes.
The management has appointed Sally Turvey as the person with responsibility for data protection compliance within the company. She can be contacted at firstname.lastname@example.org Questions about this policy, or requests for further information, should be directed to her.
“Personal data” is any information that relates to a living individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and genetic and biometric data.
“Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.
Data Protection Principles
Clock House Farm processes HR-related personal data in accordance with the following data protection principles. The Company:
As a data subject, individuals have a number of rights in relation to their personal data.
Subject access requests:
Individuals have the right to make a subject access request. If an individual makes a subject access request, the company will tell him/her:
The company will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.
To make a subject access request, the individual should send the request to email@example.com In some cases, the company may need to ask for proof of identification before the request can be processed. The company will inform the individual if it needs to verify his/her identity and the documents it requires.
The company will normally respond to a request within a period of one month from the date it is received. In some cases, such as where the company processes large amounts of the individual’s data, it may respond within three months of the date the request is received. The company will write to the individual within one month of receiving the original request to tell him/her if this is the case.
If a subject access request is manifestly unfounded or excessive, the company is not obliged to comply with it. Alternatively, the company can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which the company has already responded. If an individual submits a request that is unfounded or excessive, the company will notify him/her that this is the case and whether or not it will respond to it.
Individuals have a number of other rights in relation to their personal data. They can require the company to:
To ask the company to take any of these steps, the individual should send the request to firstname.lastname@example.org
The company takes the security of HR-related personal data seriously. The company has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.
Where the company engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
If the company discovers that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. The company will record all data breaches regardless of their effect.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.
International data transfers
The company will not transfer HR-related personal data to countries outside the EEA.
Individuals are responsible for helping the company keep their personal data up to date. Individuals should let the company know if data provided to the company changes, for example if an individual moves to a new house or changes his/her bank details.
Individuals may have access to the personal data of other individuals [and of our customers and clients] in the course of their employment. Where this is the case, the company relies on individuals to help meet its data protection obligations to staff [and to customers and clients].
Individuals who have access to personal data are required:
Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the company’s disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.
The company will provide training to all individuals about their data protection responsibilities as part of the induction process [and at regular intervals thereafter].
Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.