Data Protection Policy
Effective date: 4th July 2020
means the General Data Protection Regulation.
Register of Systems
means a register of all systems or contexts in which personal data is processed by Succeed In Property Ltd.
1. Data Protection Principles
2. General Provisions
- This policy applies to all personal data processed by Succeed In Property Ltd.
- The Administration team shall take responsibility for Succeed In Property Ltd’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually by a Data Protection Officer (Steve Johnston) or when legislation changes and forces us to amend the policy
3. Lawful, Fair and Transparent Processing
- To ensure its processing of data is lawful, fair and transparent, Succeed In Property Ltd shall maintain a systematic filing system and ensure all information is easily accessible if an individual desires to access their personal data.
- Individuals have the right to access their personal data and any such requests made to Succeed In Property Ltd shall be dealt with in a timely manner.
4. Lawful Purposes
- All data processed by Succeed In Property Ltd must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data. (Upon a customer signing Terms and Conditions this is then classed as evidence of opt-in consent).
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Succeed In Property Ltd’s systems.
5. Data Minimisation
1. Succeed In Property Ltd shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- Succeed In Property Ltd shall take reasonable steps to ensure personal data is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
- In the case of employees a “Change of Information” form is available if their information changes in order to comply with GDPR in keeping data up-to-date and accurate.
7. Archiving / Removal
1. To ensure that personal data is kept for no longer than necessary, Succeed In Property Ltd shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
2. The archiving policy shall consider what data should/must be retained, for how long, and why.
1. Succeed In Property Ltd shall ensure that personal data is stored securely using anti-virus software that is kept-up-to-date and where appropriate password protect the relevant areas / documents.
2. Access to personal data shall be limited to personnel who need access and appropriate security will be in place to avoid unauthorised sharing of information.
3. When personal data is deleted this should be done safely such that the data is irrecoverable.
4. Appropriate backup and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Succeed In Property Ltd shall promptly assess the risk to people’s rights and freedoms and follow the Data Breach Response and Notification Procedure, fill in the Data Breach Register, and notify the Data Subjects.