Douglas Hill needs to gather and use certain information about individuals.
These can include (current and former) 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 firm’s
data protection standards – and to comply with the law.
Why this policy exists
This data protection policy ensures Douglas Hill:
• Complies with data protection law and follows good practice.
• Protects the rights of employees, customers 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 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) describe how organisations – including Douglas Hill – must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other
To comply with the law, personal information must be collected and used fairly, stored safely
and not disclosed unlawfully.
The Data Protection Act 1998 and General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) are underpinned by eight 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 protected in appropriate ways
8. Not be transferred outside the European Economic Area (EEA), unless that country or
territory also ensures an adequate level of protection
People, Risks and Responsibilities
This policy applies to:
• The head office of Douglas Hill
• All branches of Douglas Hill
• All employees and Directors of Douglas Hill
• All contractors, suppliers and other people working on behalf of Douglas Hill
It applies to all data that the firm holds relating to the identifiable individuals, even if that
information technically falls outside of the Data Protection Act 1998 and the General Data
Protection Regulation (GDPR) (Regulation (EU) 2016/679). 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 Douglas Hill from some very real data security risks,
• 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
firm uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully
gained access to sensitive data.
Everyone who works for or with Douglas Hill 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 Douglas Hill meets
its legal obligations.
The Data Protection Officer is responsible for:
• Keeping the Directors updated about data protection responsibilities, risks and issues.
• 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 policy.
• Handling data protection questions from employees and anyone else covered by this
• Dealing with requests from individuals to see the data Douglas Hill 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 data.
• Ensuring all systems, services and equipment used for storing data meet acceptable
• Performing regular checks and scans to ensure security hardware and software is
• Evaluating any third-party services the company is considering using to store or process
data. For instance, cloud computing services.
• Approving data protection statements attached to communications such as emails and
• Addressing any data protection queries from journalists or media outlets like
• Where necessary, working with other employees 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.
• Douglas Hill 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 firm 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 of.
• Employees should request help from their line manager or the data protection officer if
they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing
data safely can be directed to the IT Manager / 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 and to original copies of documents:
• When not required, the paper or file 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 printer.
• Data printouts should be shredded and disposed of securely when no longer required.
• Paper Documents, especially originals of official purpose such as certificates or similar
must be sent using tracked delivery services which obtain a signature upon delivery.
• Documents sent outside the UK should always be sent by a reputable international
courier using tracked delivery services which obtain a signature upon delivery.
• When data is stored electronically, it must be protected from unauthorised access,
accidental deletion and malicious hacking attempts.
• All computers should have encrypted local disk drives.
• Data should be protected by strong passwords that are changed regularly and never
shared between employees.
• Data stored on USB drives, CD’s or DVD’s is not permitted. Any data sent to us in these
formats should be given to IT for transfer to the correct secure storage location and the
media should then be properly destroyed.
• Data should only be stored on designated drives and servers and should only be
uploaded to an approved cloud computing service.
• Servers 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 firm’s standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or
• All servers and computers containing data should be protected by approved security
software and a firewall.
Personal data is of no value to Douglas Hill 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.
The law requires Douglas Hill 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 Douglas Hill 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
• Staff should take every opportunity to ensure data is updated. For instance, by
confirming a customer’s details when they call.
• Douglas Hill will make it easy for data subjects to update the information
they about them; for example, via regular contact and review
• 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
• It is the marketing manager’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 Douglas Hill are entitled to:
• Ask what information the firm 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 firm requesting this information, this is called a subject access
Subject access requests from individuals should be made by email, addressed to the data
controller firstname.lastname@example.org. The data controller can supply a standard request form, although individuals do not have to use this.
Individuals may be charged £10 per subject access request. The data controller will aim to
provide the relevant data within 30 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 and the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Douglas Hill will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the Directors and from the firm’s legal advisers where necessary.
Douglas Hill 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 firm has a general privacy statement setting out how data relating to
individuals is used by the firm.
Douglas Hill conduct work for clients in a range of areas and must collect data for
this purpose. This privacy notice explains how we use any personal information we collect
What information do we collect about you?
We collect information about you when you engage us for advice or services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide
feedback to us.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the
performance of our contract with you. The information that we collect about you is essential
for us to be able to carry out the services that you require from us effectively. Without
collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we’ll obtain your explicit consent in order to collect
and process this information.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you
Who might we share your information with?
If you agree, we may email you about other products or services that we think may be of
interest to you.
If you agree, we’ll pass on your contact information to our group of companies so that they
may offer you their products and services.
We won’t share your information for marketing purposes with any third party.
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services or other credentialed specialist advisers.
Where third parties are involved in processing your data we’ll have a contract in place with
them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use
appropriate security measures to protect your personal data in transit.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes and this search will be recorded as an identity check. It will not affect your ability to obtain credit.
How long do we keep hold of your information?
In principle, your personal data shouldn’t be held for longer than is required under the terms
of our contract for services with you. However, we’re subject to regulatory requirements to
retain data for specified minimum periods, usually between 7 and 10 years. We also reserve
the right to retain data for longer than this in order to be able to provide you with long term
analyses, trends and reports or other business data and to allow us to assist you should you be subject to an HMRC enquiry or investigation.
You have the right to request deletion of your personal data. We’ll comply with this request,
subject to the restrictions of our regulatory obligations and legitimate interests as noted
How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you’d like a
copy of some or all of your personal information, please email or write to us using the contact details noted below.
When your personal data is processed by automated means you have the right to ask us to
move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date.
Please ask us to correct or remove any information that you think is incorrect.
We’d like to send you information about our products and services which may be of interest to you. If you agree to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes or giving
your information to other members of the group. If you no longer wish to be contacted for
marketing purposes, please contact us by email or post.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection.
In the UK this is:
Information Commissioner’s Office
0303 123 1113 (local rate)
27th March 2019.
How to contact us
about you: by email to email@example.com
Or write to us at: