DATA POLICY

 

inance4U Group  is fully committed to compliance with the requirements of the Data Protection Act 1998 (“the Act”), which came into force on 1st March 2000   Finance4U Group will therefore follow procedures that aim to ensure that all employees, clients, suppliers or any other who have access to any personal data held by or on behalf of Finance4U Group, are fully aware of and abide by their duties and responsibilities under the Act.


This policy sets out how we seek to protect to protect personal data and ensure that staff understand the rules governing their use of personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Office (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.


This policy should be read in conjunction with our Privacy Policy.

Finance4U Group  collects information about data subjects who have opted in to receive information either via its own web site or third party web sites which have been diligently checked. These may include members of the public, current, past and prospective employees, clients and customers, and suppliers. In addition, it may be required by law to collect and use information in order to comply with the requirements of central government. This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means, and therefore are safeguards within the Act to ensure this.


Finance4U Group regards the lawful and correct treatment of personal information as very important to its successful operations and to maintaining confidence between Finance4U Group and those with whom it carries out business. Finance4U Group will ensure that it treats personal information lawfully and correctly. To this end Finance4U Group fully endorses and adheres to the Principles of Data Protection as set out in the Data Protection Act 1998

Policy Owner The group policy owner for this policy is the  Graham Daniels. Proprietor

 

Definitions

Business purposes
The purposes for which personal data may be used by us:
Personal, administrative, marketing for products in which data subjects  have expressed an interest of which they have agreed to be informed, financial, regulatory, payroll and business development purposes.

Business purposes include the following: –

 

Compliance with our legal, regulatory and corporate governance obligations and good practice

Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests

Ensuring business policies are adhered to (such as policies covering email and internet use)

Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking.

Investigating complaints

Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments

Monitoring staff conduct, disciplinary matters

Marketing our business

Improving services

Personal data

‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of that natural person.

Personal data we gather may include: individuals’ phone number, email address, financial and pay details, and details of  marital status.

Special categories of personal data

Special categories of data include information about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings, and genetic and biometric information – any use of special categories of personal data should be strictly controlled in accordance with this policy.

 

Data controller

‘Data Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law.


Data processor

‘Processor’ means a natural or legal person, public authority, agency or other body which processors personal data on behalf of the controller.

 

Processing

‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available alignment or combination, restriction, erasure or destruction.

 

Supervisory authority

This is the natural body responsible for data protection. The supervisory authority for our organisation is the Information Commissioners Office (ICO).


Scope

This policy applies to all staff, who must be familiar with this policy and comply with its terms.

This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.

 

Who is responsible for this policy?

As our Data Protection Officer (DPO), Graham Daniels  has overall responsibility for the day-to-day implantation of this policy. You should contact the DPO for further information about this policy if necessary. You may contact him via our contact form CLICK HERE


The principles

Finance4U Group shall comply with the principles of data protection (the Principles) enumerated in the EU General Data Protection Regulation (GDPR). We will make every effort possible in everything we do to comply with these principles.

 

The Principles are:

1. Lawful, fair and transparent Data Collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be

2.  Limited for its purpose Data can only be collected for a specific purposes

3,  Data minimisation Any data collected must be necessary and not excessive for its purpose

4.  Accurate
The data we hold must be accurate and kept up to date

5. Retention
We cannot store data longer than necessary

6. Integrity and confidentiality
The data we hold must be kept safe and secure.

 

Data Security
Data is kept on secure cloud based servers and password protected whenever transferred individual files.

 

Accountability and transparency

We must ensure accountability and transparency in all our use of personal data. We must show how we comply with each Principle. You are responsible for keeping a written record of how all the data processing activities you are responsible for comply with each of the Principles. This must be kept up to date and must be approved by the DPO.

 

To comply with data protection laws and the accountability and transparency Principle of GDPR, we must demonstrate compliance. You are responsible for understanding your particular responsibilities to ensure we meet the following data protection obligations:

 

Fully implement all appropriate technical and organisational measures

Maintain up to date and relevant documentation on all processing activities

Conducting Data Protection Impact Assessments

Implement measures to ensure privacy by design and default including:

Data minimisation

Pseudonymisation

Transparency

Allowing individuals to monitor processing

Creating and improving security and enhanced privacy procedures on an ongoing basis

 

Our Procedures

Fair and lawful processing

We must process personal data fairly and lawfully in accordance with individuals’ rights under the first Principle. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening. We are committed to treating customers and business contacts fairly and welcome any feedback in respect of the same.

If we cannot apply a lawful basis (explained below), our processing does not conform to the first principle and will be unlawful. Data subjects have the right to have any data unlawfully processed erased.

 

Controlling vs. processing data

Finance4U Group  is classified as a data controller and data processor. We must maintain our appropriate registration with the Information Commissioners Office in order to continue lawfully controlling and processing data.


As a data processor, we must comply with our contractual obligations and act only on the documented instructions of the data controller. If we at any point determine the purpose and means of processing out with the instructions of the controller, we shall be considered a data controller and therefore breach our contract with the controller and have the same liability as the controller.

As a data processor we must:

 

Not use a sub-processor without written authorisation of the data controller

Co-operate fully with the ICO or other supervisory authority

Ensure the security of the processing

Keep accurate records of processing activities

Notify the controller of any personal data breaches

If you are in any doubt about how we handle data, contact the DPO for clarification.

Lawful basis for processing data

We must establish a lawful basis for processing data. Ensure that any data you are responsible for managing has a written lawful basis approved by the DPO. It is your responsibility to check the lawful basis for any data you are working with and ensure all of your actions comply with the lawful basis. At least one of the following conditions must apply whenever we process personal data:

 

Consent

We hold recent, clear, explicit, and defined consent for the individual’s data to be processed for a specific purpose.

 

Contract

The processing is necessary to fulfil or prepare a contract for the individual.

 

Legal obligation

We have a legal obligation to process the data (excluding a contract).

Vital interests

Processing the data is necessary to protect a person’s life or in a medical situation.

Public function

Processing necessary to carry out a public function, a task of public interest or the function has a clear basis in law.

Legitimate interest

The processing is necessary for our legitimate interests. This condition does not apply if there is a good reason to protect the individual’s personal data which overrides the legitimate interest.

 

Deciding which condition to rely on
If you are making an assessment of the lawful basis, you must first establish that the processing is necessary. This means the processing must be targeted, appropriate way of achieving the stated purpose. You cannot rely on a lawful basis if you can reasonably achieve the same purpose by some other means.
Remember that more than one basis may apply, and you should rely on what will best for the purpose, not what is the easiest.

Data Protection Registration Number:  ZB638471

​info@finance4ugroup.co.uk