Data Protection Policy (GDPR compliant)

This policy
We are committed to being transparent about how we collect and use the personal data
of our colleagues, and in meeting our data protection obligations. This policy sets out our
commitment to data protection, and individual rights and obligations in relation to
personal data.

Who is the policy for?
The policy applies to the personal data of all job applicants, employees, contractors,
apprentices, and former employees, referred to as HR-related personal data.
This policy does not apply to the personal data of clients or other personal data
processed for business purposes.

What is covered in this policy?
● Responsibility for ISM Data Protection
● Definitions
● Data Protections Principles
● Your rights
● Data Security
● Data Breaches
● Employment terms and conditions

Who is responsible for this policy?
HR Advisor

Original Policy Date
April 2018

Review frequency
Once every 3 years or in line with changes in legislation affecting this policy
ISM has appointed Katie Wood as the person with responsibility for HR data protection
compliance within the organisation. She can be contacted at
Any questions about this policy, or requests for further information, should be directed to

Personal data” is any information that relates to a living individual who can be
identified from that information. Processing is any use that is made of data, including
collecting, storing, amending, disclosing or destroying it.

Special categories of personal data” means information about an individual’s racial
or ethnic origin, political opinions, religious or philosophical beliefs, trade union
membership, health, sex life or sexual orientation and biometric data.

Criminal records data” means information about an individual’s criminal convictions
and offences, and information relating to criminal allegations and proceedings.

Data protection principles
We process HR-related personal data in accordance with the following data protection

● We will process personal data lawfully, fairly and transparently.
● We will collect personal data only for specified, explicit and legitimate purposes.
● We will process personal data only where it is adequate, relevant and limited to what is
necessary for the purposes of processing.
● We will keep accurate personal data and take all reasonable steps to ensure that
inaccurate personal data is rectified or deleted without delay.
● We will only keep personal data for the period necessary for processing.
● We will adopt appropriate measures to make sure that personal data is secure, and
protected against unauthorised or unlawful processing, accidental loss, destruction or

We inform our colleagues the reasons for processing their personal data; how we use
this data and the legal basis for processing it in our privacy notices. It will not process
personal data of individuals for other reasons. Where the organisation relies on its
legitimate interests as the basis for processing data, it will carry out an assessment to
ensure that those interests are not overridden by the rights and freedoms of individuals.

When we are required to process special categories of personal data or criminal
records data to perform our obligations to clients or to exercise rights in employment
law, this is done in accordance with a policy on special categories of data and criminal
records data.

When you let us know that your HR–related personal data has changed or is inaccurate,
ISM will update your information promptly.

Personal data gathered during your employment with us will be held in your individual
personnel file. This may be in hard copy, electronic format, or both; and on our HR and
payroll systems. The periods for which we hold HR-related personal data are contained in
our privacy notices to individuals.

We keep a record of our processing activities in respect of HR-related personal data in
accordance with the requirements of the General Data Protection Regulation (GDPR).

Individual rights
As a data subject, you have a number of rights in relation to your personal data.

Subject access requests

You have the right to make a subject access request, which is the right to see data we
hold relevant to you. If you make a subject access request, we will tell you:
● whether or not your data is processed and if so why, the categories of personal data
concerned and the source of the data if it is not collected directly from you;
● to whom your data is or may be disclosed, including to recipients located outside the
European Economic Area (EEA) and the safeguards that apply to such transfers;
● for how long your personal data is stored (or how that period is decided);
● your rights to rectification or erasure of data, or to restrict or object to processing;
● your right to complain to the Information Commissioner if you think the we have failed
to comply with your data protection rights; and
● whether or not we carry out automated decision-making and the logic involved in any
such decision-making.

ISM will also provide you with a copy of the personal data undergoing processing. This
will normally be in electronic form if you have made a request electronically, unless you
agree otherwise.

If you want additional copies, we will charge a fee, which will be based on the
administrative cost to us of providing the additional copies.
To make a subject access request, you should send the request to or use the ISM form for making a subject access request. In
some cases, we may need to ask for proof of identification before the request can be
processed. We will inform you if we need to verify your identity to provide documents

We will normally respond to a request within a period of one month from the date it is
received. Occasionally it may take more than one month to respond to your request. We
will write to you within one month of receiving the original request to tell you if this is
the case, and will then respond within three months of receipt of the original request.

We are not required to comply with any subject access requests that are manifestly
unfounded or excessive. We may agree to respond but will charge a fee, which will be
based on the administrative cost of responding to such a request. This may be the case
when a subject access request repeated and to which we have already responded. If you
submit an unfounded or excessive request, we will let you know and whether or not we
will respond to it.

Other rights
You have a number of other rights in relation to your personal data where you can
inform us to:
● rectify inaccurate data;
● stop processing or erase data that is no longer necessary for the purposes of processing;
● stop processing or erase data if your interests override the our grounds for
processing data (where we rely on our legitimate interests as a reason for processing
● stop processing or erase data if processing is unlawful; and
● stop processing data for a period if data is inaccurate or if there is a dispute about
whether or not your interests override our legitimate grounds for processing data.

To request any of these steps to be taken you should send your request to

Data security
We take the security of HR-related personal data seriously and have internal policies and
controls in place to protect your personal data against loss, accidental destruction,
misuse or disclosure, and to ensure that data is not accessed, except by employees in
the proper performance of their duties.

Where we engage third parties to process personal data on its behalf, such parties do so
on the basis of written instructions, are under a duty of confidentiality and are obliged to
implement appropriate technical and organisational measures to ensure the security
of data.

Data breaches
If ISM discovers that there has been a breach of HR-related personal data that poses a
risk to the rights and freedoms of individuals, it will report it to the Information
Commissioner within 72 hours of discovery. We will record all data breaches regardless
of their effect.

If the breach is likely to result in a high risk to your rights and freedoms we will tell you
that there has been a breach and provide you with information about any likely
consequences and the mitigation measures we have taken.

International data transfers
The organisation will not transfer HR-related personal data to countries outside the EEA.
Individual responsibilities

We are all responsible for helping the business by keeping your personal data up to date.
You should let us know if data provided to us changes, for example if you move house or
change your bank details.

In your role you may have access to the personal data of other colleagues, as well as of
our customers and clients. Where this is the case, we rely on you to help meet our data
protection obligations to each other and to customers and clients.
Where you have access to personal data are required:
● to only access data that you have authority to access and only for authorised purposes;
● not to disclose data except to individuals (whether inside or outside the organisation)
who have appropriate authorisation;
● to keep data secure (for example by complying with rules on access to premises,
computer access, including password protection, and secure file storage and
● not to remove personal data, or devices containing or that can be used to access
personal data, from the organisation’s premises without adopting appropriate security
measures (such as encryption or password protection) to secure the data and the
● not to store personal data on local drives or on personal devices that are used for work
purposes; and
● to report any data breaches of which they are aware to Katie Wood, HR Advisor

Further details about our security procedures can be found in our data security policy.
Failure to follow these requirements may result in disciplinary action, which will be dealt
with under our disciplinary procedure. Significant or deliberate breaches of this policy,
such as accessing employee or customer data without authorisation or a legitimate
reason to do so, may constitute gross misconduct and could lead to summary dismissal.

We will provide training to all individuals about their data protection responsibilities as
part of the induction process and at regular intervals thereafter.
Those whose roles require regular access to personal data, or who are responsible for
implementing this policy or responding to subject access requests under this policy, will
receive additional training to help them understand their responsibilities and how to
comply with them.