Real People Casting needs to gather and use certain information about
These can include customers, suppliers, business contacts, employees and other
people the organisation has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and
stored to meet the company's data protection standards – and to comply with the
2. Why this policy exists
This data protection policy ensures Real People Casting:
- Complies with data protection law and follow good practice
- Protects the rights of staff, customers and partners
- Is open about how it stores and processes individuals' data
- Protect itself from the risks of a data breach
3. Data Protection Law
The General Data Protection Regulations 2018 (GDPR 2018) describes how
organisations – including Real People Casting – must collect, handle and store
These rules apply regardless of whether data is stored electronically, on paper
or on other materials.
To comply with the law, personal information must be collected and used fairly,
stored safely and not disclosed unlawfully.
The GDPR is underpinned by six important principles. These say that personal
- Be processed fairly, lawfully and in a transparent manner
- Be obtained for specified, explicit and legitimate purposes
- Be adequate, relevant and limited to what is necessary
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in an appropriate manner to maintain security
4. People, Risks and Responsibilities
4.1 Policy Scope
This policy applies to:
- The office of Real People Casting
- All staff and volunteers of Real People Casting
- All contractors, suppliers and other people working on behalf of Real People Casting
It applies to all data that the company holds relating to identifiable
individuals, even if that information technically falls outside the GDPR. This
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- any other information relating to individuals
4.2 Data Protection Risks
This policy helps to protect Real People Casting from some very real data
security risks, including:
- Breaches of confidentiality. For instance, information being given out
- Failing to offer choice. For instance, all individuals should be free to
choose how the company uses data relating to them.
- Reputational damage. For instance, the company could suffer if hackers
successfully gained access to sensitive data.
Everyone who works for or with Real People Casting has some responsibility for
ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and
processed in line with this policy and other data protection policies.
However, these people have key areas of responsibility:
- The board of directors is ultimately responsible for ensuring Real People
Casting meets its legal obligations.
The [data protection officer], Lizzie Knowles, is responsible for:
- Keeping the board updated about data 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
- Handling data protection questions from staff and anyone else covered by this
- Dealing with request from individuals to see the data [company name] holds
about them (also called 'subject requests').
- Checking and approving any contracts or agreements with third parties that
may handle the company's sensitive data.
The [IT manager], Lizzie Knowles, is responsible for:
- Ensuring all systems, services and equipment used for storing data meet
acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software
is functioning properly.
- Evaluating any third-party services the company is considering using to store
or process data. For instance, cloud computing services.
The [marketing manager], Lizzie Knowles, is responsible for:
- Approving any data protection statements attached to communications such as
emails and letters.
- Addressing any data protection queries from journalists or media outlets like
- Where necessary, working with other staff to ensure marketing initiatives
abide by data protection principles.
5. 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].
- Real People Casting 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.
6. Data Storage
These rules describe how and where data should be safely stored. Questions
about storing data safely can be directed to the [IT manager/ data controller].
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 out for some reason:
- When not required, the paper or files should be kept in a locked drawer or
- 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 longer
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 (like a CD or DVD), 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 an approved cloud computing services.
- Servers containing personal data should be sited in a secure location, away
from the 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 servers and computers containing data should be protected by approved
security software and a firewall.
7. Data Use
Personal data is of no value to Real People Casting unless the business can
make use of it. However, it is when 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. The IT
manager can explain how to send data to authorised external contacts.
- Personal data may be transferred outside the EEA but only under specific
circumstances and in accordance with the GDPR.
- Employees should not save copies of personal data to their own computers.
Always access and update the central copy of any data.
8. Data Accuracy
The law requires Real People Casting to take responsible steps to ensure data
is kept accurate and up to date. The more important it is that the personal
data is accurate, the greater the effort Real People Casting should be into
ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable
steps to ensure it is kept as accurate and up to date 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 customer's details when they call.
- Real People Casting will make it easy for data subjects to update the
information Real People Casting holds about them. [By emailing
[email protected] – with the subject 'data request'].
- Data should be updated as inaccuracies are discovered. For instance, if a
customer can no longer be reached on their stored telephone number, it should
be removed from the database.
- It is the [marketing manager's] responsibility to ensure marketing databases
are checked against industry suppression files every six months.
9. Subject Access Requests
All individuals who are the subject of personal data held by Real People
Casting are entitled to:
- Ask what information the company 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 contacts the company requesting this information, this is
called a subject access request.
Subject access requests from individuals should be made by email, addressed to
the data controller at [email protected] The data controller can
supply a standard request form, although individuals do not have to use this.
The data controller must provide the relevant data within 14 days.
The data controller will always verify the identity of anyone making a subject
access request before handing over any information.
10. Disclosing data for other reasons
In certain circumstances, the GDPR allows personal data to be disclosed to law
enforcement agencies without the consent of the data subject.
Under these circumstances, Real People Casting will disclose requested data.
However, the data controller will ensure the request is legitimate, seeking
assistance from the board and from the company's legal advisers where
11. Providing Information
Real People Casting aims to ensure that individuals are aware that their data
is being processed, and that they understand:
- How the 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.