Privacy policy

Policy Review Date: 10^th May 2018

Introduction

Monks Estate & Letting Agents needs to gather and use certain information about individuals. These can include clients, applicants, purchasers, suppliers, contractors, 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 Company’s Data Protection standards and to comply with the law.

Why this policy exists

This policy ensures that Monks Estate & Letting Agents Limited

Complies with data protection law and follows good practice
Protects with rights of staff, clients, applicants, tenants, purchasers, contractors, suppliers and partners
Is open about how it stores and processes individuals’ data
Protects itself from the risks of a data breach

Data Protection Law

The Data Protection Act 1998 describes how organisations – including Netsource Ltd – 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.

Policy Scope

This policy applies to:

All offices of Monks Estate & Letting Agents Ltd
All staff of Monks Estate & Letting Agents Ltd
All contractors, suppliers and other people working on behalf of Monks Estate & Lettings Ltd

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

Names of individuals
Postal addresses
Email addresses
Telephone numbers
Any other information relating to individuals.

Data Protection risks

This policy helps to protect Monks Estate & Letting Agents Ltd from some very real data security risks, including:

Breaches of confidentiality (e.g information given out inappropriately)
Failing to offer choice (e.g. individuals should be free to choose how the company uses data relating to them)
Reputational damage (e.g. the company could suffer if hackers successfully gained access to sensitive data)

Responsibilities

Everyone who works for or with Monks Estate & Letting Agents Ltd has some responsibility for ensuring data is collected, stored and handled appropriately. Each employee 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 Directors is ultimately responsible for ensuring that Monks Estate & Letting Agents Ltd meets its legal obligations.

The Data Protection Officer (Patricia Baila, Director) is responsible for:

Keeping the rest of the Directors up to date about data protection responsibilities, risks and issues.
Reviewing all data protection
Arranging data protection training and advice for the people covered by this policy
Dealing with requests from individuals to see the data that Monks Estate & Letting Agetns Ltd holds about them (also called Subject Access Requests)
Ensuring all systems, services and equipment used for storing data meet acceptable security standards
Performing regular checks and scans to ensure security hardware and software is functioning properly
Evaluation any third party services that company is considering using to store or process data.
Approving any data protection statements attached to communications such as emails and letters
Addressing any data protection queries from journalists or media outlets like newspapers
Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General Staff Guidelines

The only people able to access data covered by this policy should be those who need it for their work.
Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
Monks Estate & Letting Agents Limited will provide training to all employees to help them understand their responsibilities when handling data.
Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
In particular, strong passwords must be used and they should never be shared.
Personal data should not be disclosed to unauthorised people, either within the company or externally.
Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
For company mobile phone user, the phone must have a passcode and no photos with any personal information should be stored on the phone, i.e. passports, utility bill, or any other personal information.

Data Storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the 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:

When not required, the paper or files should be kept in a locked drawer or filing cabinet
Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer
Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

Data should be protected by strong passwords that are changed regularly and never shared between employees.
If data is stored on removable media, like a pendrive, CD, etc., these should be kept locked away securely when not being used.
Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing service.
Servers/backups containing personal data should be sited in a secure location, away from general office space.
Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
Data should never be saved directly to laptops or other mobile devices like tablets or smartphones. For laptop users, please ensure you always work on your remote access so all the information is stored on your profile and backed up on the server.
All servers and computers containing data should be protected by approved security software and a firewall.

Data Use

Personal data is of no value to Monks Estate & Letting Agetns 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:

When working with personal data, employees should ensure the screens of their computers are always locked when left unattended
Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
Personal data should never be transferred outside of the European Economic Area.
Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
Employees should report immediately the loss of any Company data, laptop or mobile phone

Data Retention

Personal data processed for any purpose or purposes shall not be kept for longer than is necessary. Monks Estate & Letting Agents reviews the length of time that personal data is kept, on a regular basis, considering the purpose or purposes for which the data is held and for how long. Any data that is no longer needed is updated, archived or securely deleted.

Data Accuracy

The law requires Monks Estate & Letting Agetns 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 Monks Estate & Letting Agents 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.

Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
Staff should take every opportunity to ensure data is updated. For instance, by confirming a clients’s details when they call.
Monks Estate & Letting Agents will make is easy for data subjects to update the information Monks Estate & Letting Agents holds about them. For instance, via the company website.
Data should be updated as inaccuracies are discovered. For instance, if a client can no longer be reached on their stored telephone number, it should be removed from the database.
It is the marketing manager/Directors’ responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject Access Requests

All individuals who are the subject of personal data held by Monks Estate & Letting Agents are entitled to:

Ask what information the company holds about them and why
Ask how to gain access to it
Be informed how to keep it up to date
Be informed how the company is meeting its data protection obligations.

If an individual contacts the company 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: data@monks.co.uk . The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Monks Estate & Letting Agents will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.

Providing Information

Monks Estate & Letting Agents aims to ensure that individuals are aware that their data is being processed and that they understand:

How the data is being used
How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company. This is available on request. A version of this Privacy Notice statement is also available on the company’s Website, www.monks.co.uk