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Policy Statement
Save a Life Training is committed to a policy of protecting the rights and privacy of individuals (includes learners, staff and others) in accordance with the Data Protection Act. Save a Life Training needs to process certain information about its staff, learners, clients and other individuals or organisations it has dealings with for administrative purposes (e.g., to recruit and pay staff, to administer programmes of training, to agree awards, to collect fees, and to comply with legal obligations to funding bodies and government). To comply with the law, information about individuals must be collected and used fairly, stored safely and securely and not disclosed to any third party unlawfully.
The policy applies to all staff and students of Save a Life Training any breach of the Data Protection Act 1998 or the Save a Life Training Data Protection Policy is considered to be an offence in that event, Save a Life Training disciplinary procedures will apply. As a matter of good practice, other agencies and individuals working with Save a Life Training Services, and who have access to personal information, will be expected to have read and comply with this policy. It is expected that Company staff or Associates who deal with external agencies will take responsibility for ensuring that such agencies sign a contract agreeing to abide by this policy.
Background to the Data Protection Act 1998
The Data Protection Act 1998 enhance and broadens the scope of the Data Protection Act 1984. Its purpose the rights and privacy of living individuals and to ensure that personal data is not processed without their knowledge, and, wherever possible, is processed with their consent.
Definitions (Data Protection Act 1998)
Personal Data, id number. Also includes expression of opinions about the individual, and of the intentions of the data controller in respect of that individual.
Sensitive Data
Different from ordinary personal data (such as name, address, telephone) and relates to racial or ethnic origin, political opinions, religious beliefs, trade union memberships, health, sex life, criminal convictions. Sensitive data are subject to much stricter conditions of processing.
Data Controller
Any person (or organisation) who makes decisions with regard to particular personal data, including decisions regarding the purposes for which personal data are processed and the way in which the personal data are processed
Data Subject
Any living individual who is the subject of personal data held by an organisation.
Processing
Any operation related to organisation, retrieval, disclosure and deletion of data and includes: Obtaining and recording data Accessing, altering, adding to, merging, deleting data Retrieval, consultation or use of data Disclosure or otherwise making available of data.
Third Party
Any individual/organisation other than the data subject, the data controller (Save a Life Training) or its agents.
Relevant Filing System
Any paper filing system or other manual filing system which is structured so that information about an individual is readily accessible. Please note that this is the definition of “Relevant Filing System” in the Act. Personal data as defined, and covered, by the Act can be held in any format, electronic (including websites and emails), paper-based, photographic etc. from which the individual’s information can be readily extracted.
Responsibilities under the Data Protection Act
Save a Life Training as a body corporate is the data controller under the new Act.
A Data Protection Officer, Robert Howard, has been appointed who is responsible for day-to-day data protection matters and for developing specific guidance notes on data protection issues for members of Save a Life Training
All Company Directors are members of the Company Data Protection Advisory Group (DPAG) which has been established to advise on data protection issues and provide support for the Data Protection Officer.
Compliance with data protection legislation is the responsibility of all members and Associates of Save a Life Training who process personal information.
Members of Save a Life Training are responsible for ensuring that any personal data supplied to Save a Life Training are accurate and up-to-date
Notification
Notification is the responsibility of the Registrar and the Data Protection Officer. Details of Save a Life Training notification are published on Information Commissioner’s website. Anyone who is, or intends, processing data for purposes not included in Save a Life Training Notification should seek advice from the Data Protection Officer.
Data Protection Principles
All processing of personal data must be done in accordance with the eight data protection principles.
1. Personal data shall be processed fairly and lawfully.
Those responsible or processing personal data must make reasonable efforts to ensure that data subjects are informed of the identity of the data controller, the
purpose(s) of the processing, any disclosures to third parties that are envisaged and an indication of the period of which the data will be kept.
2. Personal data shall be obtained for specific and lawful purposes and not processed in a manner incompatible with those purposes.
Data obtained for specified purposes must not be used for a purpose that differs from those.
3. Personal data shall be adequate, relevant and not excessive in relation to the purpose for which it is held.
Information, which is not strictly necessary for the purpose for which it is obtained, should not be collected. If data are given or obtained which is excessive for the purpose, they should be immediately deleted or destroyed.
4. Personal data shall be accurate and, where necessary, kept up to date.
Data, which are kept for a long time, must be reviewed and updated as necessary. No data should be kept unless it is reasonable to assume that they are accurate. It is the responsibility of individuals to ensure that data held be Save a Life Training is accurate and up to date. Completion of an appropriate registration or application form etc. will be taken as an indication that the data contained therein is accurate. Individuals should notify Save a Life Training of any changes in circumstances to enable personal records to be updated accordingly. It is the responsibility of Save a Life Training to ensure that any notification regarding change of circumstances is noted and acted upon.
5. Personal data shall be kept only for as long as necessary.
6. Personal data shall be processed in accordance with the right of data subjects under the Data Protection Act
7. Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of data.
8. Personal data shall not be transferred to a country or a territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects n relation to the processing of personal data.
Data must not be transferred outside of the European Economic Area (EEA) – the fifteen EU Member States together with Iceland, Liechtenstein and Norway – without the explicit consent of the individual. Members of Save a Life Training Services LTD should be particularly 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 website that can be accessed from outside the EEA.
Data Subject Rights
Data Subjects have the following rights regarding data processing, and the data that is recorded about them:
To make subject access requests regarding the nature of information held and to whom it has been disclosed.
To prevent processing likely to cause damage or distress.
To prevent processing for purposes of direct marketing.
To be informed about mechanics of automated decision-making process that will significantly affect them.
Not to have significant decisions that will affect them taken solely by automated process.
To sue for compensation if they suffer by any contravention of the Act.
To take action to rectify, block, erase or destroy inaccurate data.
To request the Commissioner to assess whether any provision of the act has been contravened.
Consent
Wherever possible, personal data or sensitive data should not be obtained, held, used or disclosed unless the individual has given consent. Save a Life Training understands “consent” to mean that the data subject has been fully informed of the intended processing and has signified their agreement, whilst being in a fit state of mind to do so and without pressure being exerted upon them. Consent obtained under duress or on the basis of misleading information will not be as signing a form and the individual must sign the form freely of their own accord. Consent as cannot be inferred from non-response to a communication. For sensitive data, explicit written consent of data subjects must be obtained unless an alternative basis for processing exists.
In most instances consent to process personal and sensitive data is obtained routinely by Save a Life Training (e.g., when a student signs a registration form or when a new member of staff signs a contract of employment). Any Save a Life Training forms (whether paper-based or web-based0 that gather data on an individual should contain a statement explaining what the information is to be used for and to whom it may be disclosed. It is particularly important to obtain specific consent if an individual’s data are to be published on the internet as such data can be accessed from all over the globe. Therefore, not gaining consent could contravene the eighth data protection principle.
If an individual does not consent to certain types of processing (e.g., direct marketing), appropriate action must be taken to ensure that the processing does not take place.
If any members of Save a Life Training is in any doubt of these matters, they should consult the Save a Life Training Data Protection Officer.
Security of Data
All staff are responsible for ensuring that any personal data (on others) which they hold are kept securely and that they are not disclosed to any unauthorised third party.
All personal data should be accessible only to those who need to use it. You should form a judgement based upon the sensitivity and value of the information in question, but always consider keeping personal data:
in a lockable room with controlled access, or
in a locked drawer or filing cabinet, or
if computerised, password protected, or
kept on disks which are themselves kept securely
Care should be taken to ensure that PCs and terminals are not visible except to authorised staff and that computer password are kept confidential. PC screens should not be left unattended without password protected screen-savers and
manual records should not be left where they can be accessed by unauthorised personnel.
Care must be taken to ensure that appropriate security measures are in place for the deletion or disposal of personal data. Manual records should be shredded or disposed of as “confidential waste”. Hard drives of redundant PCs should be wiped clean before disposal.
This policy also applies to staff and students who process personal data “off-site”. Off-site processing presents a potentially greeters’ risk of loss, theft or damage to personal data. Staff should take particular care when processing personal data at home or in other locations outside the Save a Life Training office(s).
Rights of Access to Data
Members of Save a Life Training have the right to access any personal data which are held by Save a Life Training in electronic format and manual records which form part of a relevant filing system. This includes the right to inspect confidential personal references received by Save a Life Training about that person.
Any individual wo wishes to exercise this right should apply in writing to the Data Protection Officer. Save a Life Training reserves the right to charge a fee for data subject access requests (currently £10). Any such request will normally be complied with within 14 days of receipt of the written request and, where appropriate, the fee.
In order to respond efficiently to subject access requests Save a Life Training needs to have in place appropriate records management practices. These processes will be recorded in the Company Quality Assurance Manual.
Disclosure of Data
Save a Life Training must ensure that personal data are not disclosed to unauthorised third parties which includes family members, friends, government bodies, and in certain circumstances, the Police. All staff and learners should exercise caution when asked to disclose personal data held on another individual to a third party. For instance, it would usually be deemed appropriate to disclose a colleague’s work contact details in response to an enquiry regarding a particular function for which they are responsible. However, it would not usually be appropriate to disclose a colleague’s work details to someone who wished to
contact them regarding a non-work-related matter. The important thing to bear in mind is whether or not disclosure of the information s relevant to, and necessary for the conduct of Save a Life Training business. Best practice, however, would be to take the contact details of the person making the enquiry and pass them onto the member of Save a Life Training concerned.
This policy determines that personal data may be legitimately disclosed where one of the following conditions apply:
1. the individual has given their consent (e.g., a learner/member of staff has consented to Save a Life Training corresponding with a named third party);
2. where the disclosure is in the legitimate interests of the organisation (e.g., disclosure to staff – personal information can be disclosed to other Save a Life Training employees/associates if it is clear that those members of staff/associates require the information to enable them to perform their jobs);
3. where the institution is legally obliged to disclose the data (e.g., ethnic minority and disability monitoring);
4. where disclosure of data is required for the performance of a contract (e.g., informing a learner’s employer or sponsor of course changes/withdrawal etc).
The Act permits certain disclosures without consent so long as the information is requested for one or more of the following purposes:
to safeguard national security*;
prevention or detection of crime including the apprehension or prosecution of offenders*;
assessment or collection of tax duty*;
discharge of regulatory functions (includes health, safety and welfare of people at work) *;
to prevent serious harm to a third party;
to protect the vital interests of the individual, this refers to life and death situations.
* Requests must be supported by appropriate paperwork
When members of staff receive enquiries as to whether a named individual is a member of Save a Life Training, the enquirer should be asked why the information is required. If consent for disclosure as mot been given and the reason is not one detailed above (i.e., consent not required), the member of staff should decline to comment. Even confirming whether or not an individual is a member of Save a Life Training may constitute an unauthorised disclosure.
Unless consent has been obtained from the data subject, information should not be disclosed over the telephone. Instead, the enquirer should be asked to provide documentary evidence to support their request. Ideally a statement from the data subject consenting to disclosure to the third party should accompany the request.
As an alternative to disclosing personal data, Save a Life Training may offer to do one of the following:
pass a message to the data subject asking them to contact the enquirer
accept a sealed envelope/incoming email message and attempt to forward it to the data subject.
Please remember to inform the enquirer that such action will be taken conditionally: i.e., “if the person is a member of Save a Life Training” to avoid confirming their membership of, their presence in or their absence from the institution.
If in doubt, staff should seek advice rom the Save a Life Training Data Protection Officer.
Retention and Disposal of Data
Save a Life Training discourages the retention of personal data for longer than they are required. Considerable amounts of data are collected on current staff and learners. However, once a member of staff or learner has left the Company or training, it will not be necessary to retain all the information held on them. Some data will be kept for longer periods than others.
Learners
In general, electronic learner records containing information about individual students are kept indefinitely and information would typically include name and
address on entry and completion, programmes taken, examination results, awards obtained.
Staff
In general, electronic staff records containing information about individual members of staff are kept indefinitely and information would typically include name and address, positions held, leaving salary. Other information relating to individual members of staff will be kept by the Personnel Director for 6 years from the end of employment. Information relating to Income Tax, Statutory Maternity Pay etc. will be retained for the statutory time period (between 3 and 6 years). Departments should regularly review the personal files of individual staff members to ensure that only necessary information is retained.
Information relating to unsuccessful applicants in connection with recruitments to a post must be kept for 12 months from the interview date. Personnel may keep a record of names of individuals that have applied for, be short-listed, or interviewed, for post indefinitely. This is to aid management of the recruitment process.
Disposal of Records
Personal data must be disposed of in a way that protects the rights and privacy of data subjects (e.g., shredding, disposal as confidential waste, secure electronic deletion).
Publication of Save a Life Training Information
All members of Save a Life Training should not that Save a Life Training publishes a number of items that include personal data and will continue to do so. These personal data are:
Information published in the Save a Life Training calendar including:
Internal Telephone Directory.
Student pass lists including, where appropriate, grades.
Information in prospectuses (including photographs), annual reports, staff newsletter, etc.
Staff information on the Save a Life Training website (including photographs).
It is recognised that there might be occasions when a member of staff, a learner, or an associate member of Save a Life Training, requests that their personal details in some of these categories remain confidential or are restricted t internal access. All individuals should be offered an opportunity to opt-out of the publication of the above (and other) data. In such instances, Save a Life Training should comply with the request and ensure that appropriate action is taken.
Directing Marketing
Any department or section that uses personal data for direct marketing purposes must inform data subjects of this at the time of collection of the data. Individuals must be provided with the opportunity to object to the use of a data for direct marketing purposes (e.g., an opt-out box on a form).
Use of CCTV
Save a Life Training use of CCTV is regulated by a separate code of practice.
For reasons of personal security and to protect Save a Life Training premises and the property of staff and students, close circuit television cameras are in operation in certain locations. The presence of these cameras may not be obvious. This policy determines that personal data obtained during monitoring will be processed as follows:
any monitoring will be carried out only by a limited number of specified staff;
the recording will be accessed only by the Security Manager,
personal data obtained during monitoring will be destroyed as soon as possible after any investigation is complete.
staff involved in monitoring will maintain confidentiality in respect of personal data.
Customer Service Policy
Save a Life Training aim is to provide advice, guidance and support to learners in the security industry:
in identifying training needs for individuals and organisations
in delivering the high-quality training required for professional security personnel
in ways that suit individual learning styles
in order to develop individual skills and enhance the reputation and professionalism of individuals and organisations
Our commitment to our clients is to:
offer a range of courses and workshops to suit the diverse nature of our clients’ requirements
create appropriate supporting materials in response to our clients’ needs and to make these available in a variety of formats
provide services that are confidential and friendly
provide services that are cost-effective
make and maintain links with appropriate bodies to ensure the best outcomes for our clients in respect f qualifications
evaluate our services, courses and workshops on an ongoing basis and develop, improve and adjust them in line with the strategic aims of Save a Life Training and in response to feedback from users
ensure our training team participate in continuous professional development as necessary to deliver excellence for our clients
You can help us to accomplish this by:
treating our staff and other delegates using our services with courtesy
arriving on time and properly prepared for courses and workshops
ensuring we are aware at the time of booking of any special needs or requirements individuals delegates may have
giving us feedback on our services that we can use to improve them. You can do this by fully completing the course/workshop evaluation form or by contacting the office manager on 0208 911 8554