GDPR Statement

“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 

procedures.  

  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 

Email: alan@alantech.co.uk