The purpose of this document is to provide a concise policy statement regarding the data protection obligations of Katz Auto Services Ltd. This includes obligations in dealing with personal data in order to ensure that the organisation complies with the requirements of the relevant legislation, namely the Data Protection Act.
Katz Auto Services Ltd must comply with the data protection principles set out in the relevant legislation. This policy applies to all personal data collected, processed and stored by Katz Auto Services Ltd in relation to its staff, service providers and clients in the course of its activities. Katz Auto Services Ltd makes no distinction between the rights of data subjects who are employees, and those who are not. All are treated equally under this policy.
The policy covers both personal and sensitive personal data held in relation to data subjects by Katz Auto Services Ltd. The policy applies equally to personal data held in manual and automated form.
All personal data and sensitive personal data will be treated with equal care by Katz Auto Services Ltd. Both categories will be equally referred to as personal data in this policy, unless specifically stated otherwise.
Katz Auto Services Ltd as a Data Controller
In the course of its daily organisational activities, Katz Auto Services Ltd acquires, processes and stores personal data in relation to:
- Employees of Katz Auto Services Ltd
- Customers of Katz Auto Services Ltd
- Third party service providers engaged by Katz Auto Services Ltd
The personal data we collect and process from our customers include:
- Telephone number
- Mobile number
- Email address
The personal data we collect from our customers will be used for the following purposes:
- Raising invoices for work carried out
- Sending reminders
- Sending estimates
- Sending out occasional promotions
Consent is required for Katz Auto Services Ltd to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by contacting Katz Auto Services Ltd directly and completing the consent withdrawal form or via the Optly dashboard.
In accordance with the relevant data protection legislation, this data must be acquired and managed fairly. Not all staff members will be expected to be experts in data protection legislation. However, Katz Auto Services Ltd is committed to ensuring that its staff has sufficient awareness of the legislation in order to be able to anticipate and identify a data protection issue, should one arise. In such circumstances, staff must ensure that the Data Protection Officer is informed in order that appropriate corrective action is taken.
Due to the nature of the services provided by Katz Auto Services Ltd, there is regular and active exchange of personal data between Katz Auto Services Ltd and its data subjects. In addition, Katz Auto Services Ltd exchanges personal data with data processors on the data subjects’ behalf.
This is consistent with Katz Auto Services Ltd’s obligations under the terms of its contract with its data processors.
This policy provides the guidelines for this exchange of information, as well as the procedure to follow in the event that a Katz Auto Services Ltd staff member is unsure whether such data can be disclosed.
In general terms, the staff member should consult with the Data Protection Officer to seek clarification.
Subject Access Requests
Any formal written request made by a data subject for a copy of their personal data (a Subject Access Request) will be referred, as soon as possible, to the Data Protection Officer, and will be processed as soon as possible.
It is intended that by complying with these guidelines, Katz Auto Services Ltd will adhere to best practice regarding the applicable data protection legislation.
In the course of its role as a data controller, Katz Auto Services Ltd engages a number of data processors to process personal data on its behalf. In each case, a formal written contract is put in place with the processor, outlining their obligations in relation to the personal data, the specific purpose or purposes for which they are engaged, and the understanding that they will process the data in compliance with the data protection legislation. These data processors include:
The Data Protection Principles
The following key principles are enshrined in the legislation and are fundamental to the Katz Auto Services Ltd Data Protection Policy.
In its capacity as a data controller, Katz Auto Services Ltd ensures that all data shall:
1 … Be obtained and processed fairly and lawfully.
For data to be obtained fairly, the data subject will, at the time the data are being collected, be made aware of:
- The identity of the data controller (Katz Auto Services Ltd);
- The purpose(s) for which the data is being collected;
- The person(s) to whom the data may be disclosed by the data controller;
- Any other information that is necessary so that the processing may be fair.
Katz Auto Services Ltd will meet this obligation in the following way:
- Where possible, the informed consent of the data subject will be sought before their data is processed;
- Where it is not possible to seek consent, Katz Auto Services Ltd will ensure that collection of the data is justified under one of the other lawful processing conditions – legal obligation, contractual necessity, etc.;
- Where Katz Auto Services Ltd intends to record activity on CCTV or video, a Fair Processing Notice will be posted in full view;
- Processing of the personal data will be carried out only as part of Katz Auto Services Ltd’s lawful activities, and Katz Auto Services Ltd will safeguard the rights and freedoms of the data subject;
- The data subject’s data will not be disclosed to a third party other than to a party contracted to Katz Auto Services Ltd and operating on its behalf.
2. … Be obtained only for one or more specified, legitimate purposes.
Katz Auto Services Ltd will obtain data for purposes which are specific, lawful and clearly stated. A data subject will have the right to question the purpose(s) for which Katz Auto Services Ltd holds their data, and Katz Auto Services Ltd will be able to clearly state that purpose or purposes.
3. … Not be further processed in a manner incompatible with the specified purpose(s).
Any use of the data by Katz Auto Services Ltd will be compatible with the purposes for which the data was acquired.
4. … Be kept safe and secure.
Katz Auto Services Ltd will employ high standards of security in order to protect the personal data under its care. Appropriate security measures will be taken to protect against unauthorised access to, or alteration, destruction or disclosure of any personal data held by Katz Auto Services Ltd in its capacity as a data controller.
Access to and management of staff and customer records is limited to those staff members who have appropriate authorisation and password access.
5. … Be kept accurate, complete and up-to-date where necessary.
Katz Auto Services Ltd will:
- Ensure that administrative and IT validation processes are in place to conduct regular assessments of data accuracy;
- Conduct periodic reviews and audits to ensure that relevant data is kept accurate and up-to-date;
- Conduct a review of sample data every six months to ensure accuracy;
- Review and update staff contact details and details on next-of-kin every two years;
- Conduct regular assessments in order to establish the need to keep certain personal data.
6. … Be adequate, relevant and not excessive in relation to the purpose(s) for which the data were collected and processed.
Katz Auto Services Ltd will ensure that the data it processes in relation to data subjects are relevant to the purposes for which those data are collected. Data which are not relevant to such processing will not be acquired or maintained.
7. … Not be kept for longer than is necessary to satisfy the specified purpose(s).
Katz Auto Services Ltd has identified an extensive matrix of data categories, with reference to the appropriate data retention period for each category. The matrix applies to data in both a manual and automated format.
Once the respective retention period has elapsed, Katz Auto Services Ltd undertakes to destroy, erase or otherwise put this data beyond use.
8. … Be managed and stored in such a manner that, in the event a data subject submits a valid Subject Access Request seeking a copy of their personal data, this data can be readily retrieved and provided to them.
Katz Auto Services Ltd has implemented a Subject Access Request procedure by which to manage such requests in an efficient and timely manner, within the timelines stipulated in the legislation.
Data Subject Access Requests
As part of the day-to-day operation of the organisation, Katz Auto Services Ltd’s staff engage in active and regular exchanges of information with data subjects. Where a formal request is submitted by a data subject in relation to the data held by Katz Auto Services Ltd, such a request gives rise to access rights in favour of the data subject.
There are specific timelines within which Katz Auto Services Ltd must respond to the data subject, depending on the nature and extent of the request.
Katz Auto Services Ltd’s staff will ensure that, where necessary, such requests are forwarded to the Data Protection Officer in a timely manner, and they are processed as quickly and efficiently as possible, but within not more than one month from receipt of the request.
As a data controller, Katz Auto Services Ltd ensures that any entity which processes personal data on its behalf (a data processor) does so in a manner compliant with the applicable data protection legislation.
Failure of a data processor to manage Katz Auto Services Ltd’s data in a compliant manner will be viewed as a breach of contract and will be pursued through the courts.
Failure of Katz Auto Services Ltd’s staff to process personal data in compliance with this policy may result in disciplinary proceedings.
For the avoidance of doubt, and for consistency in terminology, the following definitions will apply within this Policy.