1. Document Summary

1.1 Key Details

Policy Prepared by: Andy Murphy

Approved on: 20th April 2018

Policy Operational on: 1st May 2018

Next Review Data: 1st May 2019

1.2 Introduction


Pescado Holdings and all its subsidiary businesses (referenced in this document as ‘Pescado’) need to gather and process certain information about Individuals.


These can include Customers, Suppliers, Business Contacts, employees and other people the organisation has a relationship with or may want to contact. This document with provide the policies and the procedures that the business will adhere to ensure that it remains compliant with the General Data Protection Regulation introduction into the UK on 25th May 2018.

The Document will cover how personal data is collected, handled and stored to meet the new regulation and comply with UK Law.

1.3 Why this document exists


The IT and Data Protection Policy ensures Pescado:

  • Complies with the General Data Protection Regulation 2018 and follow good practice
  • Protects the rights of staff, customers and partners
  • Is open about how it collects, stores and processes individual’s data
  • Protects itself from the risks of a data breach.

1.4 General Data Protection Regulation (GDPR)


The new General Data Protection Regulation (GDPR) is, like the Data Protection Directive (DPD), underpinned by a number of data protection principles which drive compliance. While the data protection principles under the GDPR are similar to those found in in the DPD, certain concepts are more fully developed.


GDPR has over 99 articles relating to personal data and how it is processed. A key article is Article 5 which introduces the principles on which personal data can be processed.


  • Lawfulness, Fairness and transparency

Data must be process in a lawful, fair and transparent manner

  • Purpose

Personal data shall be collected and processed in a specific and legitimate way.

  • Data Minimisation

Personal Data shall be adequate relevant and limited to what is necessary.

  • Accuracy

Data shall be accurate and where necessary, kept up to date.

  • Storage Limitation

Personal data shall be retained in a form which permits identification of data subjects for no longer than is necessary.

  • Integrity and Confidentiality

Personal data shall be processed in a manner that ensures appropriate
security of personal data.

  • Accountability

The Controller and Processer shall be responsible for and be able to
demonstrate compliance with GDPR.

2. People, Risk and Responsibilities

2.1 Policy Scope

This policy applies to:


  • The Head Office of Pescado
  • All Branch offices of Pescado
  • All Staff of Pescado
  • All Contractors, suppliers and partners who work on behalf pf Pescado.


IT applies to all data that the company holds relating to identifiable individuals, even if that information technical falls outside of GDPR. This can include:

  • Names of individuals
  • Postal address
  • Email addresses
  • Telephone numbers
  • Date of birth

2.2 Data Protection Risks

This policy helps to protect Pescado from data security risks, including:


  • Breaches of Confidentiality
  • Incorrect Processing of an individual’s data
  • Failing to offer choice
  • Reputational damage

2.3 Responsibilities

Everyone who works or with Pescado has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of Responsibility:

  • The Board of Directors of Pescado Holdings are ultimately responsible for ensuring that Pescado Holdings and all subsidiary companies meet their legal obligations.
  • The Technical Director, Andy Murphy is responsible for:
    • Keeping the board updated about data protection responsibilities, risks and issues.
    • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
    • Arranging data protection training and advice for the people covered by this policy
    • Handling Data Protection questions form staff and anyone else covered by this policy
    • Dealing with subject access requests
    • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
  • The IT Director, Dave Powell is responsible for:
    • Ensuring all systems, services and equipment used for storing data meet
      acceptable security standards.
    • Perform regular checks and scans to ensure security hardware and software is functioning properly
    • Evaluating any third-party services the company is considering with third parties that may handle the company’s sensitive data.
  • The Marketing Manager, Amanda Williams is responsible for:
    • Approving any data protection statements attached to communications such as emails or letters
    • Addressing any data protection queries from journalists or media outlets.
    • Where necessary, working with other staff to ensure marketing initiatives abide to this policy and GDPR.

3. 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.
  • Pescado 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 company or externally
  • 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.

4. Data Storage

These rules describe how and where data should be safely stored. Questions about storing data safely can directed to the IT Director, Dave Powell.


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 for some reason.


  • When not required, the paper or files should be kept in a locker drawer or filing cabinet
  • 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 longerrequired.


When Data is stored electronically, it must be protected from unauthorised access,

accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared between employees.
  • If Data is stored on removable media (DVD or USB), these should be kept locked away securely when not being used.
  • Data should only be stored on designated drives and servers, and should only be uploaded to approved cloud computing services.
  • 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 company’s standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • All severs and computers containing data should be protected by approved security software and a firewall.

5. Data Use

Personal Data is of no value to Pescado 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.
  • Personal Data should never be transferred outside of the EU.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

6. Data Accuracy

The General Data Protection Regulation requires Pescado to take reasonable steps to ensure data is kept accurate and up to date.


The more important the data is, the more important it is that it is accurate, Pescado will make a greater effort to ensuring its accuracy.


It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept accurate and up to data as possible.


  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a customers details when they call.
  • Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their sorted telephone number, it should be removed from the database.
  • IT is the marketing manager’s responsibility to ensure marketing databases are checked every six months,
  • Pescado will also purchase marketing data from sources that agree to GDPR Compliance.

7. Subject Access Requests

All Individuals who are the subject of personal data held by Pescado are entitled to:

  • Ask what information Pescado 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 contact the company requesting this information, this is called a subject access request.

Subject access requests form individuals should be made by email and addressed to
andy@pescado.co.uk (Pescado DPO) Individuals will be charged £25 per subject access request. Pescado will aim to provide the relevant information within 30 days. Pescado will always verify the identity of anyone making a subject access request before handing over any information.

8. Disclosing data for other reasons

In certain circumstances, 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, Pescado will disclose all requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisors where necessary.

9. Providing information

Pescado aims to ensure that individuals are aware that their data is being processed, and that they understand:


  • How Data is being used
  • How to exercise their rights


To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

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