Context and Overview

 Key Details

  • Policy prepared by:  Eleanor Macadam
  • Approved by Board/ Management on:                            
  • Policy became operational on: 1st May 2018
  • Next review date:1st May 2021


 Devine Homes PLC needs to gather and use certain information about individuals.  

These can include customers, suppliers, business contacts, employees and other people the organization 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 legal required standards of data protection and security.

Why this policy exists

This data protection policy ensures Devine Homes PLC:

  • Complies with data protection law and follows recommended practices
  • Protects the rights of staff, customers, sub-contractors and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risk of a data breach

Data Protection Law

The Data Protection Act 1998 and General Data Protection Regulation (GDPR) describes how organisations must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

  1. Be processed fairly and lawfully
  2. Be obtained only for specific lawful purposes
  3. Be adequate, relevant and not excessive
  4. Be accurate and kept up to date
  5. Not be held for any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. Not to be transferred outside of the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection


People, Risks and Responsibilities

Policy scope    

This policy applies to:

  • The Head Office of Devine Homes PLC
  • All staff and volunteers of Devine Homes PLC
  • All contractors, suppliers and other people working on behalf of Devine Homes PLC

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

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • Any other information relating to individuals

Data Protection Risks

 This Policy helps to protect Devine Homes PLC from some very real data security risks, Including:

  • Breach of confidentiality. Information being given out inappropriately.  
  • Failing to offer choice. All individuals should be free to choose how the company uses data relating to them.  
  • Reputation damage. The company could suffer if hackers successfully gained access to sensitive data.  


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

Everyone who works for or with Devine Homes PLC 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 data protection principals.
However, these people have key areas of responsibility:

•    The Board of Directors has unlimited responsibility for ensuring that Devine Homes PLC meets their legal obligations.

•    The (Data Protection Officer), Eleanor Macadam 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        
- Arranging data protection training and advice for people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data Devine Homes PLC holds about them (also called ‘Subject access requests’)
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
- Approving any data protection statements attached to communications such as emails and letters.
- Ensuring all systems, services and equipment used for storing data meets acceptable security standards.
- Ensuring regular checks and scans to ensure security hardware and software is functioning properly and completed by the outsourced IT company used.
- Evaluate third party services the company is considering using to store or process data. For instance, cloud computing services.
- addressing any data protection queries from journalists or media outlets like newspapers.

•    The (Sales Manager), Louise Whitney, is responsible for:
- Where necessary, working with staff members to ensure marketing initiatives abide by Data Protection Principals.


General Staff Guidelines

  • The only people able to access personal data covered by this policy should be those who need it for their work.
  • Data should not be shared informally.
  • Devine Homes PLC will provide training to all employees to help them understand their responsibilities when handling data.
  • Employees should keep all data secured, 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 unauthorized 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 there Line Manager or the Data Protection Officer, if they are unsure about any aspect of data protection.

Data Storage

The Rules describe how and where data should be safely stored. Questions about the storing of data safely can be directed to the data controller.

When data is stored on paper it should be kept in a secure place where unauthorised individuals 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 filing cabinet.
  • Employees should make sure paper and printouts are not left where unauthorized people could see them, like on a printer.
  • Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically it must be protected from unauthorized 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 approved cloud computing services.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Date should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard back up 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.

Date Use

Personal data is of no value to Devine Homes PLC 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 with individuals who do not need the data to complete their job’s.
  • Data must be encrypted before being transferred electronically. The IT provider can explain how to send data to authorized external contacts.
  • Personal data should never be transferred outside of the European Economic Area.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data Accuracy

The law requires Devine Homes PLC to take reasonable 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 Devine Homes PLC should put 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 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 the customers details when they call.
  • Devine Homes PLC will make it easy for data subjects to update the information Devine Homes PLC holds about them. For instance, Via the company website.
  • 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.

Subject to Access Requests

All individuals who are the subject of personal data held by Devine Homes PLC 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 contact’s the company requesting this information, this is called a “Subject to Access Request”.

Subject to access from individuals should be made by email, addressed to the Data Controller at The Data Controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject to access request. The Data Controller will aim to provide the relevant data within 14 days.

The Data Controller will always verify the identity of anyone making a “subject to access” requests before handing over the information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcing agencies without the consent of the data subject.

Under these circumstances Devine Homes PLC 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 adviser where necessary.

Providing information

Devine Homes PLC 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 Notice, setting out how data relating to individuals is used by the company.

(This is available on request. A version of this statement is also available on the company’s website.)