Data Protection Policy
Moorcroft Holidays shall be called “the company”.
The company needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, 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.
This web site uses SSL certificates, to ensure that any data sent to / from the web site is encrypted.
Why this policy exists
This data protection policy ensures that the company complies with:
Data protection law
The GDPR describes how organisations — including the company — 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.
The GDPR is underpinned by eight important principles. These say that personal data must:
People, risks and responsibilities
This policy applies to:
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:
Data protection risks
This policy helps to protect the company from some very real data security risks, including:
Everyone who works for or with the company has some responsibility for ensuring data is collected, stored and handled appropriately. Whomever at the company 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:
Catriona Morrison (who shall be called “the data protection officer”) is ultimately responsible for ensuring that the company meets its legal obligations.
The data protection officer is responsible for IT used at the company, including computers, laptops, mobile phones and other devices that can store personal data.
The data protection officer is responsible for any marketing related activities at the company. The data protection officer is responsible for:
General guidelines for data usage
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the data protection officer. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see or access 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. The data protection officer will 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:
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:
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. The data protection officer is 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. The data protection officer should not create any unnecessary additional data sets. The data protection officer should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call. The company will make it easy for data subjects to update the information the company holds about them. For instance, via the company website. 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 database. It is the the data protection officer’s 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 the company are entitled to:
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, using our contact us details.
There is no charge for subject access request. The company will aim to provide the relevant data within 30 days.
The company 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 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 data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
The company aims to ensure that individuals are aware that their data is being processed, and that they understand: