EURO PRO FOOTBALL LTD will need to obtain certain information from you.
We take data protection compliance very seriously. Failure to comply puts both individuals and the organisation at risk.
Our policy (see below) sets out how we assure you that we will always keep your data safe and private. We will never sell your data, and we allow you to review and change your marketing choices at any time.
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 that data and ensure that staff understand the rules governing their use of personal data to which they have access during the course of their work.
This policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any new or significant changes to data processing activity is initiated. This could be internally driven I.E. operational changes or externally driven e.g. legislative or adopted standard changes.
This policy is designed to ensure and evidence our adherence to the current applicable data protection legislation. Namely: Data Protection Act 2018 and General Data Protection Regulations.
EURO PRO FOOTBALL is a business registered, operating and processing data within the UK, with under 50 employees. This policy applies to all who we hold personal data on for business purposes.
All EURO PRO FOOTBALL staff must be familiar with this policy. This policy is displayed internally for ongoing awareness and transparency.
Given the broad scope of data protection, this policy supplements our Company Handbooks and Terms of Business. As well as our other policies and processes relating to IT Security, Data Management, Incident Control, Internet and Electronic Mail Use and our Supplier Code of Conduct.
The processing of all data must be:
Our procedures must reflect fair and lawful processing; therefore, 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, while maintaining obvious and clear methods for opt-out or un-subscription.
The board of Directors have overall responsibility for data protection.
The CEO (Carlo Di Manno) is our designated Data Protection Officer (DPO) and has overall responsibility for the day-to-day implementation of this policy.
Data Protection Specifics
IT Systems & Arrangements
Sales & Marketing Management
Terms of Business
Our Terms of Business contains a Data Protection Notice to clients highlighting our data protection commitment and legislative compliance. A copy of this policy can be provided to supplement those Terms of Business, upon request.
Sensitive Personal Data (EURO PRO FOOTBALL Staff primarily only) 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.
Personal data: We will take all reasonable steps to ensure that personal data we hold is accurate and updated as required.
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 they believe that information is inaccurate, we will record the fact that the accuracy of the information is disputed and inform the DPO.
Data Security & Storage
All applicable staff 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
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, but should be determined in a manner consistent with our data retention guidelines.
Subject Access Requests & Individuals Rights
Individuals are entitled by law, subject to certain exceptions or restrictions, to request access to information held about them. If we do receive a subject access request, it will be referred immediately to the DPO. Response will be issued on an as soon as possible basis, under authorisation of the CEO. This response will be issued no later than one calendar month from the initial request.
Staff should contact the DPO if they would like to correct or request information that we hold about you.
With regards to the processing of personal data, we will 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.
We do not send direct marketing material to someone electronically (IE via email) unless they are deemed to have a genuine interest i.e., we have an existing enquiry or business relationship with them, in relation to the products or services being marketed.
The DPO should be consulted for advice on direct marketing before starting any new direct marketing activity. Escalating to the CEO, where appropriate.
All staff receive training on this policy. New joiners will receive training as part of the induction process. Further training will be provided periodically or whenever there is a substantial change in the law or our policy and procedure. Completion of training is compulsory.
Training is provided through an in-house awareness seminar, which covers:
· The law relating to data protection.
· Our data protection and related policies and procedures.
Data Protection Act 2018 (GDPR) Specific Provisions
In consideration to the above legislation, where not specified previously within this policy, the following provisions were in effect on or before 25th May 2018.
Privacy Notice (Transparency of Data Protection)
Being transparent and providing accessible information to individuals about how we use their personal data is important for our organisation. We have a process that details on how we collect data and what we will do with it for any persons interested.
Conditions for Processing
We 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 are 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 process personal data in compliance with all ‘relevant’ 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.
The data that we collect is subject to active consent by the data subject. This consent can be revoked at any time, in writing or through unsubscribe mechanisms.
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 facilitated free of charge.
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 as well as ensuring that all data protection applicable projects commence I.E. IT, 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.
Data Audit and Register
Regular data audits to manage and mitigate risks will inform the data register. We have a register detailing 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.
All members of staff have an obligation to report any actual or potential data protection compliance failures (data breach). This will be reported to the DPO, investigated and handled as an Internal Non-Conformance. This allows us to:
Everyone throughout the company must observe and abide by this policy. The DPO will monitor and review the policy periodically to ensure compliance.
This policy statement will be reviewed for continuing suitability annually.
Carlo Paolo Di Manno