Shorts Financial Services needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people the organisation 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 firm’s data protection standards – and to comply with the law.
This data protection policy ensures Shorts Financial Services:
The Data Protection Act 2018 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) describe how organisations – including Shorts Financial Services – 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 2018 and General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) are underpinned by eight important principles. These say that personal data must:
This policy applies to:
It applies to all data that the firm holds relating to the identifiable individuals, even if that information technically falls outside of the Data Protection Act 2018 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679). This can include:
This policy helps to protect Shorts Financial Services from some very real data security risks, including:
Everyone who works for or with Shorts Financial Services 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 Data Protection Officer, is responsible for:
The IT Manager is responsible for:
The Marketing Manager is responsible for:
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT Manager / Data Controller.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason and to original copies of documents:
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
Personal data is of no value to Shorts Financial Services 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:
The law requires Shorts Financial Services 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 Shorts Financial Services 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.
All individuals who are the subject of personal data held by Shorts Financial Services are entitled to:
If an individual contacts the firm 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 privacy@shorts.uk.com. The data controller can supply a standard request form, although individuals do not have to use this.
Individuals may be charged £10 per subject access request. The data controller will aim to provide the relevant data within 30 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
In certain circumstances, the Data Protection Act and the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Shorts Financial Services will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the Partners and from the firm’s legal advisers where necessary.
Shorts Financial Services aims to ensure that individuals are aware that their data is being processed and that they understand:
To these ends, the firm has a privacy statement, setting out how data relating to individuals is used by the firm.