Privacy Statement

 THE ANVG DATA PROTECTION POLICY

Introduction

We hold personal data about our employees, clients, suppliers and other individuals for a variety of business purposes.

This policy sets out how we seek to protect personal data and ensure that staff understand the rules governing their use of personal data to which they have access in the course of their work.

Definitions

Business purposes

   The purposes for which personal data may be used by us:

Personnel, administrative, financial, regulatory, payroll and business development purposes.

Business purposes include the following:

- Compliance with our legal, regulatory and corporate

governance obligations and good practice

- Gathering information as part of investigations by

regulatory bodies or in connection with legal proceedings

or requests

- Ensuring business policies are adhered to (such as

policies covering email and internet use)

- Operational reasons, such as recording transactions,

training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking

- Investigating complaints

- Checking references, ensuring safe working practices,

monitoring and managing staff access to systems and facilities and staff absences, administration and assessments

- Monitoring staff conduct, disciplinary matters

- Marketing our business

- Improving services

  Personal data

   Information relating to identifiable individuals, such as job applicants, current and former employees, agency, contract and other staff, clients, suppliers and marketing contacts.

Personal data we gather may include: individuals' contact details, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title and CV.

  Sensitive personal data

    Personal data about an individual's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non- membership), physical or mental health or condition, criminal offences, or related proceedings—any use of sensitive personal data should be strictly controlled in accordance with this policy.

   ANVG

Data Protection Policy 8/6/2022


 

 Scope

This policy applies to all staff. You must be familiar with this policy and comply with its terms.

This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.

Who is responsible for this policy?

As our Data Protection Officer, Becky Wright has overall responsibility for the day-to- day implementation of this policy.

Our procedures

Fair and lawful processing

We must process personal data fairly and lawfully in accordance with individuals’ rights. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.

The Data Protection Officer’s responsibilities:

• Reviewing all data protection procedures and policies on a regular basis

• Arranging data protection training and advice for all staff members and those

included in this policy

• Answering questions on data protection from staff and stakeholders

• Responding to individuals such as clients and employees who wish to know

which data is being held on them by New Leaf Life Design

• Checking and approving with third parties that handle the company’s data any

contracts or agreement regarding data processing

Responsibilities of the IT Manager

• Ensure all systems, services, software and equipment meet acceptable security standards

• Checking and scanning security hardware and software regularly to ensure it is functioning properly

• Researching third-party services, such as cloud services the company is considering using to store or process data

Responsibilities of the Marketing Manager

• Approving data protection statements attached to emails and other marketing copy

• Addressing data protection queries from clients, target audiences or media outlets

• Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy


 

 The processing of all data must be:

• Necessary to deliver our services

• In our legitimate interests and not unduly prejudice the individual's privacy

• In most cases this provision will apply to routine business data processing

activities.

Our Terms of Business contains a Privacy Notice to clients on data protection. The notice:

• Sets out the purposes for which we hold personal data on customers and employees

• Highlights that our work may require us to give information to third parties such as expert witnesses and other professional advisers

• Provides that customers have a right of access to the personal data that we hold about them

Sensitive personal data

In most cases where we process sensitive personal data we will require the data subject's explicit consent to do this unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.

Accuracy and relevance

We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO

Your personal data

You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required. For example, if your personal circumstances change, please inform the Data Protection Officer so that they can update your records.

Data security

You must keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will


 


 

 establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third party organisations.

Storing data securely

• In cases when data is stored on printed paper, it should be kept in a secure place where unauthorised personnel cannot access it

• Printed data should be shredded when it is no longer needed

• Data stored on a computer should be protected by strong passwords that are changed regularly. We encourage all staff to use a password manager to

create and store their passwords.

• Data stored on CDs or memory sticks must be locked away securely when

they are not being used

• The DPO must approve any cloud used to store data

• Servers containing personal data must be kept in a secure location, away

from general office space

• Data should be regularly backed up in line with the company’s backup

procedures

• Data should never be saved directly to mobile devices such as laptops,

tablets or smartphones

• All servers containing sensitive data must be approved and protected by

security software and strong firewall.

Data retention

We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained. Where information is required to be retained by law this period will be up to 5 years.

Subject access requests

Please note that under the Data Protection Act 1998, individuals are entitled, subject to certain exceptions, to request access to information held about them.

If you receive a subject access request, you should refer that request immediately to the DPO. We may ask you to help us comply with those requests.

Please contact the Data Protection Officer if you would like to correct or request information that we hold about you. There are also restrictions on the information to which you are entitled under applicable law.

Processing data in accordance with the individual's rights

You should abide by any request from an individual not to use their personal data for direct marketing purposes and notify the DPO about any such request.

Do not send direct marketing material to someone electronically (e.g. via email) unless you have an existing business relationship with them in relation to the services being marketed.


 

 

 Please contact the DPO for advice on direct marketing before starting any new direct marketing activity.


 


 

 Training

All staff will receive training on this policy. New joiners will receive training as part of the induction process. Further training will be provided at least every two years or whenever there is a substantial change in the law or our policy and procedure.

Training is provided through an in-house seminar on a regular basis. It will cover:

• The law relating to data protection

• Our data protection and related policies and procedures.

Completion of training is compulsory.

GDPR provisions

Where not specified previously in this policy, the following provisions will be in effect on or before 6/6/22

Privacy Notice - transparency of data protection

Being transparent and providing accessible information to individuals about how we will use their personal data is important for our organisation. The following are details on how we collect data and what we will do with it:

How is it collected?

       What information is being collected?

Name, Address, Date of Birth

    Who is collecting it?

ANVG

   Data maybe collected via Telephone,

 email, www.ANVG.co.uk. In terms of social

  media Each social media channel has their own policy

 on the way they process your personal data when you

 access their sites. We do not collect cookies ourselves

 however if in the future this changes and you choose to

 watch one of our videos on YouTube, you will be asked

  for explicit consent to accept YouTube cookies; if you

  look at our Twitter activity on Twitter, you will be asked

 for explicit consent to accept Twitter cookies; the same

  applies for LinkedIn. Our Facebook pages are publicly

  viewable. We ask consent to use photographs and if

 Why is it being collected?

you comment on a post your profile will remain viewable

 to other page viewers.

  Necessary to deliver our services

In our legitimate interests and not unduly prejudice the individual's privacy

In most cases this provision will apply to routine


 

  business data processing activities.

    We collect several kinds of information from visitors to www.newleaf.uk.com; what we collect is dependent on the part of the site being visited, e.g. registering for an event, training, feedback, e-mail enquiries, or participating in another site feature.

We use website tracking software to get useful statistics about online visits, but this is not personal, by this we mean that you personally (who you are) could not be tracked by it.

Cookies are pieces of data created when you visit a site, and contain a unique, anonymous number. They are stored in the cookie directory of your hard drive, and do not expire at the end of your session. Cookies do not contain any personal information about you and cannot be used to identify an individual user. If you choose not to accept the cookie, this will not affect your access to the majority of facilities available on our website.

Log files allow us to record visitors’ use of the site. Log file information from all our visitors, which we use to make improvements to the layout of the site and to the information in it, based on the way that visitors move around it. Log files do not contain any personal information about you.

     How will it be used?

     We provide links to other web sites. When a link is made we open another browser window. We do not pass on any personal information as part of the linking process. New Leaf is not responsible for the privacy practices within any of these other sites. We encourage you to look for and read the privacy statements on the other websites you visit.

       Who will it be shared with?


 

  

 Details of transfers to third country and safeguards

   Any information you provide will be held securely and in accordance with the Data Protection Act. Your personal details will not be sold or traded to third parties. In limited circumstances we may need to disclose your personal details to a third party so that they can provide a service you have requested, or fulfil a request for information, we will advise you beforehand in such cases. Any information about you that we pass to a third party will be held securely by that party, in accordance with the Data Protection Act, and used only to provide the services or information you have requested

     Conditions for processing

We will ensure any use of personal data is justified using at least one of the conditions for processing and this will be specifically documented. All staff who are responsible for processing personal data will be aware of the conditions for processing. The conditions for processing will be available to data subjects in the form of a privacy notice.

Justification for personal data

We will process personal data in compliance with all six data protection principles.

We will document the additional justification for the processing of sensitive data, and will ensure any biometric and genetic data is considered sensitive.

Consent

The data that we collect is subject to active consent by the data subject. This consent can be revoked at any time.

Criminal record checks

Any criminal record checks are justified by law. Criminal record checks cannot be undertaken based solely on the consent of the subject.

Data portability

Upon request, a data subject should have the right to receive a copy of their data in a structured format. These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This must be done for free.

Right to be forgotten

A data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.


 


 

 Privacy by design and default

Privacy by design is an approach to projects that promote privacy and data protection compliance from the start. The DPO will be responsible for conducting Privacy Impact Assessments and ensuring that all IT projects commence with a privacy plan.

When relevant, and when it does not have a negative impact on the data subject, privacy settings will be set to the most private by default.

International data transfers

No data may be transferred outside of the EEA without first discussing it with the data protection officer. Specific consent from the data subject must be obtained prior to transferring their data outside the EEA.

Data audit and register

Regular data audits to manage and mitigate risks will inform the data register. This contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant.


 

Records may be kept as paper records or within IT systems. They can comprise of factual documents in respect of clients, such as contracts, letters, referrals, attendance records, fees, emails and text messages, they can also include process notes, artwork or creative materials that you keep for clients.

Data is stored securely, we ensure that any paper records are locked away, and any electronic records are:

• password protected, ideally at both the level of the individual document, as well as on the device used being password protected.

• consideration should be given to document encryption, especially if the document is to be stored remotely such as in ‘cloud based’ storage systems.

• virus protection should also be utilised in order to protect files being corrupted or hacked since this supports appropriately professional handling of the records.


 

 Reporting breaches

All members of staff have an obligation to report actual or potential data protection compliance failures. This allows us to:

• Investigate the failure and take remedial steps if necessary

• Maintain a register of compliance failures

• Notify the Supervisory Authority (SA) of any compliance failures that are

material either in their own right or as part of a pattern of failures

Please refer to our Compliance Failure Policy for our reporting procedure.

Monitoring

Everyone must observe this policy. The DPO has overall responsibility for this policy. They will monitor it regularly to make sure it is being adhered to.

Consequences of failing to comply

We take compliance with this policy very seriously. Failure to comply puts both you and the organisation at risk.

The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in dismissal. A solicitor in breach of Data Protection responsibility under the law or the Code of Conduct may be struck off.

If you have any questions or concerns about anything in this policy, do not hesitate to contact the DPO.

Alex Roland is registered with the Information Commissioner's Office under registration reference: ZB320330

 

Data Protection Policy 8th June 2022