GDPR Statement

Alantech Computers Ltd Data Protection Policy 16/05/2018

We may have to collect and use information about people with whom we work. This personal information must be handled and dealt with 
properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means. We 
regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence 
between us and those with whom we carry out business. We will 
ensure that we treat personal information lawfully and correctly. To 
this end we fully endorse and adhere to the principles of the General 
Data Protection Regulation (GDPR). This policy applies to the 
processing of personal data in manual and electronic records kept by 
us in connection with our human resources function as described 
below. It also covers our response to any data breach and other rights under the GDPR. This policy applies to the personal data of job 
applicants, existing and former employees, apprentices, volunteers, 
placement students, workers and self-employed contractors. These are referred to in this policy as relevant individuals.    

“Personal data” is information that relates to an identifiable person 
who can be directly or indirectly identified from that information, for 
example, a person’s name, identification number, location, online 
identifier. It can also include pseudonymised data.   “Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and 
trade union membership. It also includes genetic and biometric data 
(where used for ID purposes).   “Criminal offence data” is data which 
relates to an individual’s criminal convictions and offences.   “Data 
processing” is any operation or set of operations which is performed 
on personal data or on sets of personal data, whether or not by 
automated means, such as collection, recording, organisation, 
structuring, storage, adaptation or alteration, retrieval, consultation, 
use, disclosure by transmission, dissemination or otherwise making 
available, alignment or combination, restriction, erasure or destruction.  Under GDPR, all personal data obtained and held by us must be 
processed according to a set of core principles. In accordance with 
these principles, we will ensure that:   processing will be fair, lawful and transparent data be collected for specific, explicit, and legitimate 
purposes data collected will be adequate, relevant and limited to what 
is necessary for the purposes of processing data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay data is not kept for longer than is necessary for 
its given purposedata will be processed in a manner that ensures 
appropriate security of personal data including protection against 
unauthorised or unlawful processing, accidental loss, destruction or 
damage by using appropriate technical or organisation measureswe 
will comply with the relevant GDPR procedures for international 
transferring of personal data  

We keep several categories of personal data on our employees in order to carry out effective and efficient processes. We keep this data in a 
personnel file relating to each employee and we also hold the data within our computer systems, for example, our holiday booking system.   
Specifically, we hold the following types of data:   personal details such as name, address, phone numbers information gathered via the 
recruitment process such as that entered into a CV or included in a CV cover letter, references from former employers, details on your 
education and employment history etcdetails relating to pay 
administration such as National Insurance numbers, bank account 
details and tax codes medical or health information. Information 
relating to your employment with us, including: job title and job 
descriptions your salary your wider terms and conditions of 
employment details of formal and informal proceedings involving you 
such as letters of concern, disciplinary and grievance proceedings, 
your annual leave records, appraisal and performance information
internal and external training modules undertaken. All of the above 
information is required for our processing activities. More information on those processing activities are included in our privacy notice for 
employees, which is available from your manager.  

 You have the following rights in relation to the personal data we hold 
on you: the right to be informed about the data we hold on you and 
what we do with it; the right of access to the data we hold on you. More information on this can be found in the section headed “Access to 
Data” below and in our separate policy on Subject Access Requests”
;the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’; the 
right to have data deleted in certain circumstances. This is also known as ‘erasure’; the right to restrict the processing of the data; the right to 
transfer the data we hold on you to another party. This is also known 
as ‘portability’; the right to object to the inclusion of any information
;the right to regulate any automated decision-making and profiling of 
personal data.   More information can be found on each of these rights in our separate policy on employee rights under GDPR.  

  In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection. We have also appointed employees with responsibility for reviewing and auditing our data 
protection systems.


  We acknowledge that processing may be only be carried out where a 
lawful basis for that processing exists and we have assigned a lawful 
basis against each processing activity.   Where no other lawful basis 
applies, we may seek to rely on the employee’s consent in order to 
process data.   However, we recognise the high standard attached to 
its use. We understand that consent must be freely given, specific, 
informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. Employees will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to 
withdraw consent at any time.  

  As stated above, employees have a right to access the personal data 
that we hold on them. To exercise this right, employees should make a Subject Access Request. We will comply with the request without 
delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.   No charge will be made for complying with a request unless the request is 
manifestly unfounded, excessive or repetitive, or unless a request is 
made for duplicate copies to be provided to parties other than the 
employee making the request. In these circumstances, a reasonable 
charge will be applied. Further information on making a subject access request is contained in our Subject Access Request policy.  

  The Company may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:   
any employee benefits operated by third parties; disabled individuals – whether any reasonable adjustments are required to assist them at 
work ;individuals’ health data – to comply with health and safety or 
occupational health obligations towards the employee; for Statutory 
Sick Pay purposes; HR management and administration – to consider 
how an individual’s health affects his or her ability to do their job; the 
smooth operation of any employee insurance policies or pension plans
;to assist law enforcement or a relevant authority to prevent or detect 
crime or prosecute offenders or to assess or collect any tax or duty.   
These kinds of disclosures will only be made when strictly necessary 
for the purpose.  

All our employees are aware that hard copy personal information 
should be kept in a locked filing cabinet, drawer, or safe.Employees are aware of their roles and responsibilities when their role involves the 
processing of data. All employees are instructed to store files or 
written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access 
them and to ensure that screen locks are implemented on all PCs, 
laptops etc when unattended. No files or written information of a 
confidential nature are to be left where they can be read by 
unauthorised people.   Where data is computerised, it should be coded, encrypted or password protected both on a local hard drive and on a 
network drive that is regularly backed up. If a copy is kept on 
removable storage media, that media must itself be kept in a locked 
filing cabinet, drawer, or safe.   Employees must always use the 
passwords provided to access the computer system and not abuse 
them by passing them on to people who should not have them.   
Personal data relating to employees should not be kept or transported on laptops, USB sticks, or similar devices, unless prior authorisation 
has been received. Where personal data is recorded on any such 
device it should be protected by:   ensuring that data is recorded on 
such devices only where absolutely necessary.using an encrypted 
system — a folder should be created to store the files that need extra 
protection and all files created or moved to this folder should be 
automatically encrypted.ensuring that laptops or USB drives are not 
left where they can be stolen.   Failure to follow the Company’s rules on data security may be dealt with via the Company’s disciplinary 
procedure. Appropriate sanctions include dismissal with or without 
notice dependent on the severity of the failure.    

  Where we engage third parties to process data on our behalf, we will 
ensure, via a data processing agreement with the third party, that the 
third party takes such measures in order to maintain the Company’s 
commitment to protecting data.  

The Company does not transfer personal data to any recipients 
outside of the EEA.    

  All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information 
Commissioner within 72 hours of discovery. In addition, where legally 
required, we will inform the individual whose data was subject to 
breach.   More information on breach notification is available in our 
Breach Notification policy.  

    New employees must read and understand the policies on data 
protection as part of their induction.   All employees receive training 
covering basic information about confidentiality, data protection and 
the actions to take upon identifying a potential data breach.   
The nominated data controller/auditors/protection officers for the 
Company are trained appropriately in their roles under the GDPR.   
All employees who need to use the computer system are trained to 
protect individuals’ private data, to ensure data security, and to 
understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and 

  The Company keeps records of its processing activities including the purpose for the processing and retention periods in its HR Data 
Record. These records will be kept up to date so that they reflect 
current processing activities.  

 Our Data Protection Officer is:   Alan Baxter   44 Church Street Audley Staffordshire ST7 8DE   Telephone: 07971 008880 

This policy has been approved and authorised by:

Name: Alan Baxter

Position: Director

Date: 16.05.2018