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Cosmetic Couture
Last updated: 3 October 2021
Definitions
Company: Cosmetic Couture
GDPR: General Data Protection Regulation
Responsible Person: Maxine Hopley
Register of Systems: a register of all systems or contexts in which personal data is processed by the company
1. Data protection principles
The Company is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
- Processed lawfully, fairly and in a transparent manner in relation to individuals.
- Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay.
- Kept in a form which permits identification of data subjects for no longer than is necessary. Data may be stored longer for archiving, research, or statistical purposes subject to safeguards that protect rights and freedoms.
- Processed in a manner that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
2. General provisions
This policy applies to all personal data processed by the Company.
The Responsible Person shall take responsibility for ongoing compliance with this policy.
This policy shall be reviewed at least annually.
The Company shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
To ensure processing is lawful, fair and transparent, the Company shall maintain a Register of Systems.
The Register shall be reviewed at least annually.
Individuals have the right to access their personal data and any such requests shall be dealt with in a timely manner.
4. Lawful purposes
All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests
(see ICO guidance for more information).
The Company shall note the appropriate lawful basis in the Register of Systems.
Where consent is relied upon, evidence of opt-in consent shall be kept with the personal data.
Where communications are sent based on consent, the option to revoke consent shall be clearly available and systems in place to reflect such revocation.
5. Data minimisation
- The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
6. Accuracy
The Company shall take reasonable steps to ensure personal data is accurate.
Where necessary, steps shall be put in place to ensure that personal data is kept up to date.
7. Archiving / Removal
To ensure data is kept no longer than necessary, the Company shall put in place an archiving policy and review this annually.
The policy shall consider what data must be retained, for how long, and why.
8. Security
The Company shall ensure that personal data is stored securely using modern software that is kept up to date.
Access to personal data shall be limited to personnel who need it, with appropriate security in place to prevent unauthorised sharing.
When personal data is deleted this shall be done safely so the data is irrecoverable.
Appropriate back-up and disaster recovery solutions shall be in place.
9. Breach
In the event of a breach leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and, if appropriate, report this to the ICO.