This Policy sets out the obligations of Training and Inspection Services Ltd regarding data protection and the rights of customers and business contacts (“data subjects”) in respect of their personal data under Data Protection Act 2018 (Formally EU Regulation 2016/679 General Data Protection Regulation (“GDPR”)).
The Data Protection Act 2018 defines “personal data” as any information relating to an
identified or identifiable natural person (a “data subject”); an identifiable natural person is one
who can be identified, directly or indirectly, in particular by reference to an identifier such as a
name, an identification number, location data, an online identifier, or to one or more factors
specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of
that natural person.
This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
The Training and Inspection Services Ltd is committed not only to the letter of the law, but also
to the spirit of the law and places high importance on the correct, lawful, and fair handling of all
personal data, respecting the legal rights, privacy, and trust of all individuals with whom it
deals.
This Policy aims to ensure compliance with the Data Protection Act 2018. The Data Protection Act 2018 sets out the following principles with which any party handling personal data must comply. All personal data must be:
protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.
The Data Protection Act 2018 seeks to ensure that personal data is processed lawfully, fairly,
and transparently, without adversely affecting the rights of the data subject. The Data
Protection Act 2018 states that processing of personal data shall be lawful if at least one of the
following applies:
The data subject has given consent to the processing of their personal data for one or
more specific purposes;
The processing is necessary for the performance of a contract to which the data subject
is a party, or in order to take steps at the request of the data subject prior to entering
into a contract with them;
The processing is necessary for compliance with a legal obligation to which the data
controller is subject;
The processing is necessary to protect the vital interests of the data subject or of
another natural person;
The processing is necessary for the performance of a task carried out in the public
interest or in the exercise of official authority vested in the data controller; or
The processing is necessary for the purposes of the legitimate interests pursued by the
data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
If the personal data in question is “special category data” (also known as “sensitive
personal data”) (for example, data concerning the data subject’s health), at least one of the following conditions must be met:
The data subject has given their explicit consent to the processing of such data for one or
more specified purposes (unless EU or EU Member State law prohibits them from doing
so);
The processing is necessary to protect the vital interests of the data subject or of
another natural person where the data subject is physically or legally incapable of giving
consent;
The processing relates to personal data which is clearly made public by the data subject;
The processing is necessary for the conduct of legal claims or whenever courts are
acting in their judicial capacity;
The Training and Inspection Services Ltd collects and processes the personal data set out in this
Policy.
This includes:
Personal data collected directly from data subjects Personal data obtained from third parties.
The Company only collects, processes, and holds personal data for the specific purposes
set out in this Policy (or for other purposes expressly permitted by the Data Protection Act 2018).
Data subjects are kept informed at all times of the purpose or purposes for which the
Company uses their personal data.
The Training and Inspection Services Ltd will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will b informed).
The Company shall ensure that all personal data collected, processed, and held by it is
kept accurate and up-to-date. This includes, but is not limited to, the rectification of
personal data at the request of a data subject.
The accuracy of personal data shall be checked when it is collected and at regular
intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all
reasonable steps will be taken without delay to amend or erase that data, as appropriate.
The Company shall not keep personal data for any longer than is necessary in light of the
purpose or purposes for which that personal data was originally collected, held, and
processed.
When personal data is no longer required, all reasonable steps will be taken to erase or
otherwise dispose of it without delay.
For full details of the Company’s approach to data retention, including retention periods
for specific personal data types held by the Company, please refer to our Data Retention Policy.
The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided later in this Policy.
The Company’s Training Manager is Afshin Maaf Roodpishi
E-Mail: afshin.maaf@inspector-training.com
Tel: 0044 2082881771
The Training Manager shall be responsible for overseeing the implementation of this Policy and
for monitoring compliance with this Policy, the Company’s other data protection-related
policies, and with the Data Protection Act 2018 and other applicable data protection legislation.
The Company shall keep written internal records of all personal data collection, holding,
and processing, which shall incorporate the following information:
The name and details of the Company, its Training Manager, and any applicable third-
party data processors;
The purposes for which the Company collects, holds, and processes personal data;
Details of the categories of personal data collected, held, and processed by the Company,
and the categories of data subject to which that personal data relates;
Details of any transfers of personal data to non-EEA countries including all mechanisms
and security safeguards;
Details of how long personal data will be retained by the Company; and
Detailed descriptions of all technical and organisational measures taken by the Company
to ensure the security of personal data.
The Training and Inspection Services Ltd shall carry out Data Protection Impact
Assessments for any and all new projects and/or new uses of personal data.
Data Protection Impact Assessments shall be overseen by the training manager and
shall address the following:
The Training and Inspection Services Ltd shall provide the information set out in section (i) below to every data subject:
Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:
a) if the personal data is used to communicate with the data subject, when the first communication is made; or
b) if the personal data is to be transferred to another party, before that transfer is made; or
c) as soon as reasonably possible and in any event not more than one month after the personal data is obtained.
The following information shall be provided:
Details of the Company including, but not limited to, the identity of its training manager
The purpose(s) for which the personal data is being collected and will be processed (as
detailed in this Policy) and the legal basis justifying that collection and processing;
Where applicable, the legitimate interests upon which the Company is justifying its
collection and processing of the personal data;
Where the personal data is not obtained directly from the data subject, the categories of
personal data collected and processed;
Where the personal data is to be transferred to one or more third parties, details of
those parties;
Where the personal data is to be transferred to a third party that is located outside of
the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place,
o Details of data retention;
o Details of the data subject’s rights under the Data Protection Act 2018;
o Details of the data subject’s right to withdraw their consent to the Company’s
processing of their personal data at any time;
o Details of the data subject’s right to complain to the Information Commissioner’s
Office (the “supervisory authority” under the Data Protection Act 2018);
o Where applicable, details of any legal or contractual requirement or obligation
necessitating the collection and processing of the personal data and details of any
consequences of failing to provide it; and
o Details of any automated decision-making or profiling that will take place using the
personal data, including information on how decisions will be made, the significance
of those decisions, and any consequences.
Data subjects may make subject access requests (“SARs”) at any time to find out more
about the personal data which the Company holds about them, what it is doing with that personal data, and why.
Data subjects wishing to make a SAR may do so in writing, using the Company’s Subject
Access Request Form, or other written communication. SARs should be addressed to the
training manager at Training and Inspection Services Ltd., 163 Robin Hood Way,
London Sw15 3QG, London; Tel: 0044 208 288 1771; Email:afshin.maaf@inspector-
training.com
Responses to SARs shall normally be made within one month of receipt, however this
may be extended by up to two months if the SAR is complex and/or numerous requests
are made. If such additional time is required, the data subject shall be informed.
All SARs received shall be handled by the Company’s Training Manager.
The Company does not charge a fee for the handling of normal SARs. The Training and Inspection Services Ltd. reserves the right to charge reasonable fees for additional
copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are
repetitive.
Data subjects have the right to require the Company to rectify any of their personal data
that is inaccurate or incomplete.
The Training and Inspection Services Ltd. shall rectify the personal data in question,
and inform the data subject of that rectification, within one month of the data subject
informing the Company of the issue. The period can be extended by up to two months in
the case of complex requests. If such additional time is required, the data subject shall be
informed.
In the event that any affected personal data has been disclosed to third parties, those
parties shall be informed of any rectification that must be made to that personal data.
Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:
a) It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
b) The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
c) The data subject objects to the Company holding and processing their personal data
(and there is no overriding legitimate interest to allow the Company to continue doing
so),
d) The personal data has been processed unlawfully;
e) The personal data needs to be erased in order for the Company to comply with a particular legal obligation.
Unless the Company has reasonable grounds to refuse to erase personal data, all requests for
erasure shall be complied with, and the data subject informed of the erasure, within one month
of receipt of the data subject’s request. The period can be extended by up to two months in the
case of complex requests. If such additional time is required, the data subject shall be informed.
In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).
Data subjects may request that the Training and Inspection Services Ltd ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.
In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).
Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling) and processing for scientific and/or historical research and statistics purposes.
Where a data subject objects to the Company processing their personal data based on its
legitimate interests, the Company shall cease such processing immediately, unless it can be
demonstrated that the Company’s legitimate grounds for such processing override the data
subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of
legal claims.
Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.
Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Data Protection Act 2018, “demonstrate grounds relating to his or her particular situation”. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.
The following personal data is collected, held, and processed by the Training and Inspection Services Ltd:
Name, email address only
The Training and Inspection Services Ltd shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:
All emails containing personal data must be encrypted using Encryption software;
All emails containing personal data must be marked “confidential”;
Personal data may be transmitted over secure networks only; transmission over
unsecured networks is not permitted in any circumstances;
Personal data may not be transmitted over a wireless network if there is a wired
alternative that is reasonably practicable;
Personal data contained in the body of an email, whether sent or received, should be
copied from the body of that email and stored securely. The email itself should be
deleted. All temporary files associated therewith should also be deleted using deletion
software;
Where personal data is to be sent by facsimile transmission the recipient should be
informed in advance of the transmission and should be waiting by the fax machine to receive the data;
Where personal data is to be transferred in hardcopy form it should be passed directly
to the recipient or sent using Royal Mail Registered or 1st or 2nd Class Signed For post;
and
All personal data to be transferred physically, whether in hardcopy form or on
removable electronic media shall be transferred in a suitable container marked “confidential”.
The Company shall ensure that the following measures are taken with respect to the storage of personal data:
All electronic copies of personal data should be stored securely using passwords and
data encryption;
All hardcopies of personal data, along with any electronic copies stored on physical,
removable media should be stored securely in a locked box, drawer, cabinet, or similar; All personal data stored electronically should be backed up at least daily with backups
stored onsite. All backups should be encrypted using data encryption’
No personal data should be stored on any mobile device (including, but not limited to,
laptops, tablets, and smartphones), whether such device belongs to the Company or
otherwise without the formal written approval of the Training Manager and, in the event
of such approval, strictly in accordance with all instructions and limitations described at
the time the approval is given, and for no longer than is absolutely necessary; and
No personal data should be transferred to any device personally belonging to an
employee and personal data may only be transferred to devices belonging to agents,
contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Data Protection Act 2018 (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).
When any personal data is to be erased or otherwise disposed of for any reason (including
where copies have been made and are no longer needed), it should be securely deleted and
disposed of.
The Company shall ensure that the following measures are taken with respect to the use of personal data:
No personal data may be shared informally and if an employee, agent, sub-contractor, or
other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from The Training Manager,
No personal data may be transferred to any employees, agents, contractors, or other
parties, whether such parties are working on behalf of the Company or not, without the authorisation of The Training Manager,
Personal data must be handled with care at all times and should not be left unattended
or on view to unauthorised employees, agents, sub-contractors, or other parties at any
time;
If personal data is being viewed on a computer screen and the computer in question is to
be left unattended for any period of time, the user must lock the computer and screen before leaving it; and
Where personal data held by the Company is used for marketing purposes, it shall be the
responsibility of Afshin Maaf Roodpishi (Training Manager) to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.
The Company shall ensure that the following measures are taken with respect to IT and information security:
All passwords used to protect personal data should be changed regularly and should not
use words or phrases that can be easily guessed or otherwise compromised. All
passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols;
Under no circumstances should any passwords be written down or shared between any
employees, agents, contractors, or other parties working on behalf of the Company,
irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
All software (including, but not limited to, applications and operating systems) shall be
kept up-to-date. The Company’s IT staff shall be responsible for installing any and all
security-related updates after the updates are made available by the publisher or
manufacturer, unless there are valid technical reasons not to do so; and
No software may be installed on any Company-owned computer or device without the prior approval of the Company.
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
All employees, agents, contractors, or other parties working on behalf of the Company
shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Data Protection Act 2018 and under this Policy, and shall be provided with a copy of this Policy;
Only employees, agents, sub-contractors, or other parties working on behalf of the
Company that need access to, and use of, personal data in order to carry out their
assigned duties correctly shall have access to personal data held by the Company;
All employees, agents, contractors, or other parties working on behalf of the Company
handling personal data will be appropriately trained to do so;
All employees, agents, contractors, or other parties working on behalf of the Company
handling personal data will be appropriately supervised;
All employees, agents, contractors, or other parties working on behalf of the Company
handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
Methods of collecting, holding, and processing personal data shall be regularly evaluated
and reviewed;
All personal data held by the Company shall be reviewed periodically, as set out in the
Company’s Data Retention Policy;
The performance of those employees, agents, contractors, or other parties working on
behalf of the Company handling personal data shall be regularly evaluated and
reviewed;
All employees, agents, contractors, or other parties working on behalf of the Company
handling personal data will be bound to do so in accordance with the principles of the
Data Protection Act 2018 and this Policy by contract;
All agents, contractors, or other parties working on behalf of the Company handling
personal data must ensure that any and all of their employees who are involved in the
processing of personal data are held to the same conditions as those relevant employees
of the Company arising out of this Policy and the Data Protection Act 2018; and
Where any agent, contractor or other party working on behalf of the Company handling
personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.
The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:
o The transfer is to a country, territory, or one or more specific sectors in that country (or
an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
o The transfer is to a country (or international organisation) which provides appropriate
safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the Data Protection Act 2018); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
o The transfer is made with the informed consent of the relevant data subject(s);
o The transfer is necessary for the performance of a contract between the data subject and
the Company (or for pre-contractual steps taken at the request of the data subject);
o The transfer is necessary for important public interest reasons;
o The transfer is necessary for the conduct of legal claims;
o The transfer is necessary to protect the vital interests of the data subject or other
individuals where the data subject is physically or legally unable to give their consent; or
o The transfer is made from a register that, under UK or EU law, is intended to provide
information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.
All personal data breaches must be reported immediately to the Company’s Training Manager.
If a personal data breach occurs and that breach is likely to result in a risk to the rights
and freedoms of data subjects (e.g. financial loss, breach of confidentiality,
discrimination, reputational damage, or other significant social or economic damage),
the Training Manager must ensure that the Director is informed of the breach without
delay, and in any event, within 72 hours after having become aware of it.
In the event that a personal data breach is likely to result in a high risk to the rights and
freedoms of data subjects, the Training Manager must ensure that all affected data
subjects are informed of the breach directly and without undue delay.
Data breach notifications shall include the following information:
o The categories and approximate number of data subjects concerned;
o The categories and approximate number of personal data records concerned;
o The name and contact details of the Company’s Training Manager (or other contact
point where more information can be obtained);
o The likely consequences of the breach;
o Details of the measures taken, or proposed to be taken, by the Company to address
the breach including, where appropriate, measures to mitigate its possible adverse effects.
This policy has been approved & authorised by:
Name: Moska Maaf Roodpishi
Position: Director
Date:10th June 2021
Signature:
Review of Policy: Biannual
https://inspector-training.com ; 0044 (0) 208 288 1771
163 Robin Hood Way; London SW153QG; United Kingdom
