DATA PROTECTION POLICY

 

Introduction

The Byres Road and Lanes BID Company Limited (‘the BID’) is a Business Improvement District which works with businesses to increase the trading performance, improve the environmental quality and enhance the visitor experience of Byres Road and the surrounding lanes. The BID trades as Visit West End, and it is organisation behind the Visit West End gift card.

The personal data that the BID processes to provide these services relates to its clients and other individuals as necessary, including staff and suppliers staff.

This policy sets out the BID’s commitment to ensuring that any personal data, including special category person data, which the BID processes, is carried out in compliance with data protection law.  The BID is committed to ensuring that all the personal data that it processes is done in accordance with data protection law.  The BID ensures that a good data protection practice is imbedded in the culture of our staff and our organisation.

The BID’s other data protection policies and procedures are (these should be considered and may not all be necessary):

·         Record of processing activities

·         Privacy notices (website, client, employees)

·         Personal data breach reporting process and a breach register)

·         Data retention policy

·         Data subject rights procedure

·         Data protection impact assessment process

·         IT security policies

‘Data Protection Law’ includes the General Data Protection Regulation 2016/679; the UK Data Protection Act 2018 and all relevant EU and UK data protection legislation.

 

Scope

This policy applies to all personal data processed by the BID and is part of the BID’s approach to compliance failure with data protection law.  All BID staff are expected to comply with this policy and failure to comply may lead to disciplinary action for misconduct, including dismissal.

 

Data Protection Principles

The BID complies with the data protection principles set out below.  When processing personal data, it ensures that:

·         It is processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’)

·         It is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation)

·         It is all adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)

·         It is all accurate and, where necessary, kept up to date and that reasonable steps will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which the personal data are processed (‘storage limitation’)

·         It is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’)

The BID will facilitate any request from a data subject who wishes to exercise their rights under data protection law appropriate, always communicating in a concise, transparent, intelligible and easily accessible form and without undue delay.

 

Process/procedures/guidance

The BID will:

·         Ensure that the legal basis for processing personal data is identified in advance and that all processing complies with the law

·         Not do anything with your data that you would not expect given the content of this policy and the fair processing or privacy notice

·         Ensure that appropriate privacy notices are in place advising staff and others how and why their data is being processed, and, in particular, advising data subjects of their rights

·         Only collect and processes the personal data that it needs for purposes it has identified in advance

·         Ensure that, as far as possible, the personal data that it holds is accurate, or a system is in place for ensuring that it is kept up to date as far as possible

·         Only hold onto your personal data for as long as it is needed, after which time the BID will securely erase or delete the personal data- The BID’s data retention policy sets out the appropriate period of time

·         Ensure that appropriate security measures are in place to ensure that personal data can only be accessed by those who need to access it and that it is held and transferred securely

The BID will ensure that all staff who handle personal data on its behalf are aware of their responsibilities under this policy and other relevant data protection and information security policies, and that they are adequately trained and supervised.

Breaching this policy may result in disciplinary action for misconduct, including dismissal.  Obtaining (including assessing) or disclosing personal data in breach of the BID’s data protection policies may also be a criminal offence.

 

Data Subject Rights

The BID has processes in place to ensure that it can facilitate any request made by an individual to exercise their rights under data protection law.  All staff have received training and are aware of the rights of data subjects. Staff can identify such a request and know who to send it to.