Personal Data Policy Statement

Last Updated: 03/01/2022

Definitions

Highway Data Systems Ltd (HDS) is committed to a policy of protecting the rights and privacy of individuals, organisations and others in accordance with The Data Protection Act 1998. The policy applies to all personnel working for, on behalf of Highway Data Systems. Any breach of The Data Protection Act 1998 or this Policy is considered to be an offence and, in that event, disciplinary procedures apply.

As a matter of good practice, other organisations and individuals working with Highway Data Systems, and who have access to personal information, will be expected to have read and comply with this policy. It is expected that any staff who deal with external organisations will take responsibility for ensuring that such organisations sign a contract agreeing to abide by this policy.

Legal Requirements

Data is protected by the Data Protection Act 1998. Its purpose is to protect the rights and privacy of individuals and to ensure that personal data are not processed without their knowledge, and, wherever possible, is processed without their consent.

The Act requires us to register the fact that we hold personal data and to acknowledge the right of ‘subject access’ – organisations’ information and staff must have the right to copies of their own data.

Data Protection Principles

In terms of the Data Protection Act 1998, we are the ‘data controller’, and as such determine the purpose for which, and the manner in which, any personal data is, or will be, processed. Highway Data Systems must ensure that we have:

1. Fairly and lawfully processed personal data
   Highway Data Systems will always put our logo on all paperwork, stating their intentions on processing the data and state if, and to whom, we intend to give the personal data. Also provide an indication of the duration the data will be kept.
2. Processed for limited purpose
   We will not use data for a purpose other than those agreed by data subjects. If the data held by Highway Data Systems is requested by external organisations for any reason, this will only be passed if data subjects have agreed. Also external organisations must state the purpose of processing, agree not to copy the data for further use and sign a contract agreeing to abide by The Data Protection Act 1998 and Highway Data Systems’ Personal Data Protection Policy.
3. Adequate, relevant and not excessive
   Highway Data Systems will monitor the data held for our purposes, ensuring we hold neither too much nor too little data in respect of the individuals about whom the data is held. If data given or obtained are excessive for such purpose, they will be immediately deleted or destroyed.
4. Accurate and up-to-date
   We will provide our clients with on-line access to their data for information and updating where relevant. All amendments will be made immediately and data no longer required will be deleted or destroyed. It is the responsibility of individuals and organisations to ensure the data held by Highway Data Systems is accurate and up-to-date. Completion of an appropriate forms will be taken as an indication that the data contained are accurate. Individuals should notify us of any changes, to enable personnel records to be updated accordingly. It is the responsibility of Highway Data Systems to act upon notification of changes to data, amending them where relevant.
5. Not kept longer than necessary
   We discourage the retention of data for longer than it is required. All personal data will be deleted or destroyed by Highway Data Systems as described within the Document Control Process.
6. Processed in accordance with the individual’s rights All individuals that Highway Data Systems hold data on have the right to:

• Be informed upon the request of all the information held about them within 40 days.
• Prevent the processing of their data for the purpose of direct marketing.
• Compensation if they can show that they have been caused damage by any contravention of the Act.
• The removal and correction of any inaccurate data about them.

7. Secure
   Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of data.
   Highway Data Systems computers have a log in system and our Portal is password protected, which allow only authorised staff to access personal data. Passwords on all computers are changed frequently. All personal and financial data is kept in a locked, fire-proof filing cabinet and can only be accessed by the Executive officers. When staff members are using the laptop computers out of the office care should always be taken to ensure that personal data on screen is not visible to strangers.
8. Not transferred to countries outside the European Economic Area, unless the country has adequate protection for the individual.
   Data must not be transferred to countries outside the European Economic Area without the explicit consent of the individual. The Association takes particular care to be aware of this when publishing information on the Internet, which can be accessed from anywhere in the globe. This is because transfer includes placing data on a web site that can be accessed from outside the European Economic Area.