Data Protection Policy

1. Introduction

Ryearch needs to gather, store and use certain information about individuals. These can include customers, suppliers, 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.

2. Why this Policy Exists

This data protection policy ensures the Company:

• Complies with data protection law and follow good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach

3. Data Protection Law

The General Data Protection Regulation (GDPR) 2018 describes how organisations, including Ryearch, 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 & transparently, stored safely and not disclosed unlawfully.

The GDPR is built on the following important principles. These say that personal data must:

1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be kept safe & secure
8. Not be transferred outside the European Economic Area without adequate protection.
9. Include privacy by design
10. Have a transparent process
11. Include Informed Consent

4. Policy Scope

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR 2018. This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• plus any other information relating to individuals

5. Data Protection Risks

This policy helps to protect the Company from some very real data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive

6. Responsibilities

Everyone who works for or with the Company has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team 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 are ultimately responsible for ensuring that the Company meets its legal obligations.

The Data Protection Manager (DPM), Collette Creaven, is responsible for:

• Keeping the board updated about data protection responsibilities, risks and
• Reviewing all data protection procedures and related policies, in line with an agreed
• Arranging data protection training and advice for the people covered by this
• Handling data protection questions from staff and anyone else covered by this
• Dealing with requests from individuals to see the data the Company holds about them (also called ‘subject access requests’).
• Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive
• Ensuring all systems, services and equipment used for storing data meet acceptable security
• Performing regular checks and scans to ensure security hardware and software is functioning
• Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing
• Approving data protection statements attached to communications such as emails and
• Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles

7. General Staff Guidelines

• The only people able to access data covered by this policy should be those who need it for their
• Data should not be shared informally. When access to confidential information is required, employees can request it from their line
• The Company will provide training to all employees to help them understand their responsibilities when handling
• Employees should keep all data secure, by taking sensible precautions and following the guidelines
• 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
• 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
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data
• Ryearch do not collect special category data such as race, religion or sexual orientation.

8. Informed Consent

Consent must be obtained from individuals prior to processing (using) data outside the terms described in the Ryearch Privacy Notice (at Appendix A of this document). Consent must be freely given, specific, informed and unambiguous – a positive opt in. The he consent must be separate from other terms and conditions and may be withdrawn by applying in writing to the DPM to withdraw consent.

9. Data Storage and Security

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

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
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a
• 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
• If data is stored on removable media (USB / CD / DVD etc.), these should be kept locked away securely when not being
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing
• Servers containing personal data should be sited in a secure location, away from general office
• Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup
• Data should never be saved directly to laptops or mobile devices like tablets or smart
• All servers and computers containing data should be protected by approved security software and a firewall.

10. Data Use / Processing

Personal data is of no value to the Company 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
• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not
• Data must be encrypted before being transferred electronically. The DPM can explain how to send data to authorised external
• Personal data should never be transferred outside of the European Economic
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

11. Data Accuracy

The law requires the Company 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 the Company 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
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they
• The Company will make it easy for data subjects to update the information the Company holds about them. For instance, via the company
• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the
• It is the DPM responsibility to ensure marketing databases are checked against industry suppression files every six

12. Subject Access Requests

All individuals who are the subject of personal data held by the Company are entitled to:

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

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 DPM. The DPM can supply a standard request form, although individuals do not have to use this.

The DPM will aim to provide the relevant data within 14 days, but always within 28 days. The DPM will always verify the identity of anyone making a subject access request before handing over any information.

Where a request is refused the individual will be told why and that they have the right to complain to the supervisory authority and to a judicial remedy.

13. Disclosing Data for other Reasons

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

Under these circumstances, the Company will disclose requested data. However, the DPM will ensure the request is legitimate, seeking assistance from fellow directors and from the company’s legal advisers where necessary.

Ryearch do not share personal data, other than that required by legitimate Training Providers, Tender Submissions and Pre-Qualification Questionnaires, with third parties either inside or outside the European Union.

14. Notification of Breaches

The company maintains electronic (cyber) security through a competent sub contractor who provides and maintains up to date data protection software. All computers (including PC’s, Laptops and Tablets) are provided with and run this security software; personal data is not to be used on equipment not fitted with the latest edition of the security programme. If any doubt exists contact the DPM for clarification.

In the event of a personal data breach where the breach is likely to result in a risk to the rights and freedoms of individuals (i.e. the breach could result in discrimination, damage to reputation, financial loss, loss of confidentiality or any other significant economic or social disadvantage) the company is required to inform the Information Commissioners Office (ICO) and the individual(s) concerned.

15. The Right to be Forgotten (Erasure of Data)

All individuals have the right to request that their personal data is erased; this request can be made to the DPM either verbally or in writing, the DPM will aim to respond within 14 days but always within 28 days. There is no absolute right to be forgotten, no rights of erasure exist where the processing of data is necessary:

• To comply with legal obligations
• To establish, exercise or defend legal claims

The request will be acted upon in the following circumstances:

• When the information is no longer necessary for the original purpose
• When consent to use the data is withdrawn
• When the legitimate interest no longer applies
• When the data has been processed unlawfully
• To comply with a legal obligation

16. Lawful Basis for Processing Data

The following table describes the six areas of Lawful Basis for Processing Data required under GPDR.

Basis	Explanation
Consent	The individual has given clear explicit consent for Ryearch Ltd to process their personal data for a specific purpose
Contract	The processing is necessary for a contract that Ryearch Ltd have with the individual, or because specific steps are required for entering into a contract
Legal Obligation	The processing is necessary for Ryearch Ltd to comply with the law
Vital Interest	The processing is necessary to protect someone’s life
Public Task	The processing is necessary for Ryearch Ltd to perform a task in the public interest or the companies official functions, and the task has a clear basis in law
Legitimate Interest	The processing is necessary for Ryearch’s legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate business interests