Context and Overview

 Key Details

• Policy prepared by: Pauline Griggs
• Approved by board/management by: Sam Mountain
• Policy became operational on: 05/01/2025
• Next Review Date: 01/01/2026

 

Introduction

Intelligent Waste Management Ltd needs to gather certain information about individuals. These can include customers, suppliers, business contacts, employees, and other people the organization 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

This data protection policy ensures Intelligent Waste Management Ltd:

• Complies with data protection laws and follows good practice
• Protects the rights of staff, customers, and 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 2018 describes how organisations – including Intelligent Waste Management Ltd – 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:

• Be processed fairly and lawfully
• Be obtained only for specific, lawful purposes
• Be adequate, relevant, and not excessive
• Be accurate and kept up to date
• Not be held for any longer than necessary
• Be processed in accordance with the rights of data subjects
• Be protected in appropriate ways
• Not be transferred outside the European Economic Area (EEA), 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 Intelligent Waste Management Ltd
• All branches of Intelligent Waste Management Ltd
• All staff and volunteers of Intelligent Waste Management Ltd
• All contractors, suppliers, and other people working on behalf of Intelligent Waste Management Ltd

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 2018. This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Plus any other information relating to individuals

Data Protection Risks

This policy helps to protect Intelligent Waste Management Ltd from some very real data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, 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 data.

Responsibilities

Everyone who works for or with Intelligent Waste Management Ltd has some responsibility for ensuring 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, these people have key areas of responsibility:

• The board of directors is ultimately responsible for ensuring that Intelligent Waste Management Ltd meets its legal obligations.
• The data protection officer, Louise Drysdale, 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.
  • 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 Intelligent Waste Management Ltd holds about them (also called 'subject access requests').
  • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
  • Ensuring all systems, services, and equipment used for storing data meet acceptable security standards.
  • Approving any data protection statements attached to communications such as emails and letters.

 

General Data Protection Regulation (GDPR)

GDPR was implemented on 25th May 2018. General Data Protection Regulation 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union and the European Economic Area. Intelligent Waste Management Ltd is dedicated to complying with GDPR and will ensure all information we hold is managed with the following guidelines. We will:

• Be reasonable and correctly processed in accordance with the new regulations
• Not keep information for longer than necessary
• Handle correctly throughout the process of obtaining, processing, and storing in compliance with GDPR
• Be used for the lawful purposes and processed in a manner which has been agreed with
• Use suitable and applicable purposes for which the information is intended to be used
• Store securely and protect from unauthorized or unlawful processing or accidental loss, destruction, and damage
• Not transfer data to countries outside of the European Economic Area (EEA), unless the country/territory upholds adequate protection for the rights and freedoms of the data subjects
• Meet all legal requirements specified for the information we hold
• Ensure it is accurate and kept up-to-date
• Implement guidelines which allow records to be checked and decide how long that information needs to be held for
• Ensure quality checks/audits are regularly undertaken
• Abide by all conditions that information was provided with
• Ensure that personal information is not transferred outside the EEA without suitable safeguards

 

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.
• Intelligent Waste Management Ltd 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.
• In particular, strong passwords must be used and they should never be shared.
• Personal data should not be disclosed to unauthorized people, either within the company or externally.
• Data should be regularly reviewed and updated if it is found to be 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 the IT manager or data controller.

When data is stored on paper, it should be kept in a secure place where unauthorized 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 unauthorized people could see them, like on a printer.
• Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorized 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 CD or DVD), 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 an approved cloud computing service.
• 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 the company’s standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or smartphones.
• All servers and computers containing data should be protected by approved security software and a firewall.

 

Data Use

Personal data is of no value to Intelligent Waste Management Ltd 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 be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorized external contacts.
• Personal data should never be transferred outside of the European Economic Area.
• 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 Intelligent Waste Management Ltd 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 Intelligent Waste Management Ltd 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 will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• Intelligent Waste Management Ltd will make it easy for data subjects to update the information Intelligent Waste Management Ltd holds about them. For instance, via the company website.
• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

 

Subject Access Requests

All individuals who are the subject of personal data held by Intelligent Waste Management Ltd are entitled to:

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

If an individual contacts the company requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email, addressed to the data controller at louise@iwaste.co.uk. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days. The data controller will always verify the identity of anyone making a subject access request before handing over any information.

 

Disclosing Data for Other Reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Intelligent Waste Management Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

 

Providing Information

Intelligent Waste Management Ltd aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How the data 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. For additional information on how your data may be processed by our partners, please refer to Google’s Privacy & Terms.

For any questions regarding this privacy policy, please contact our data protection officer at louise@iwaste.co.uk.