Data Protection Policy

Introduction

BRCU is required to retain certain personal data about its customers and their nominated Key & Careholders for the purposes of satisfying operational obligations. The company recognises the importance of the correct and lawful treatment of personal data; it maintains confidence in the organisation and allows successful operations.

BRCU fully endorses and adheres to the eight principles of the Data Protection Act. These principles specify the legal conditions that must be satisfied in relation to obtaining, handling, processing, transportation and storage of personal data. Employees and any others who obtain, handle, process, transport and store personal data for the BCRU must adhere to these principles.

Principles

The principles require that personal data shall:
Be processed fairly and lawfully and shall not be processed unless certain conditions are met;
Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose;
Be adequate, relevant and not excessive for those purposes;
Be accurate and, where necessary, kept up to date;
Not be kept for longer than is necessary for that purpose;
Be processed in accordance with the data subject’s rights;
Be kept secure from unauthorised or unlawful processing and protected against accidental loss, destruction or damage by using the appropriate technical and organisational measures;
And not be transferred to a country or 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 in relation to the processing of personal data.

Satisfaction of principles

In order to meet the requirements of the principles, BRCU will:

observe fully the conditions regarding the fair collection and use of personal data;
meet its obligations to specify the purposes for which personal data is used;
collect and process appropriate personal data only to the extent that it is needed to fulfil operational or any legal requirements;
ensure the quality of personal data used;
apply strict checks to determine the length of time personal data is held;
ensure that the rights of individuals about whom the personal data is held, can be fully exercised under the Act
take the appropriate technical and organisational security measures to safeguard personal data, and ensure that personal data is not transferred abroad without suitable safeguards.

The Companies Designated Data Controller

BRCU Information Compliance Manager is responsible for ensuring compliance with the Data Protection Act and implementation of this policy on behalf of the company. The Information Compliance Manager is Neil Fisher, Operations Director, 0203 0060 461 ext 4612, Any questions or concerns about the interpretation or operation of this policy should be taken up in the first instance with the Information Compliance Manager.

Status of the Policy

This policy has been approved by the Management and any breach will be taken seriously and may result in formal action. Any employee who considers that the policy has not been followed in respect of personal data about themselves should raise the matter with their Line Manager or the companies Information Compliance Manager in the first instance.

Data Subject Access

All individuals who are the subject of personal data held by BCRU 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 what BRCU is doing to comply with its obligations under the 1998 Data Protection Act.
Data Subject Responsibilities

All data subjects are responsible for:

Ensuring that any personal data that they provide to 4bi is accurate and up to date.
Informing BCRU of any changes to information which they have provided,
e.g. changes of address.
Checking any information that BRCU may send out from time to time, giving details of information that is being kept and processed.
As part of their responsibilities BRCU employees collect information about other people as such they must comply with the Policy and with the Data Protection Act.

Data Security

The need to ensure that data is kept securely means that precautions must be taken against physical loss or damage, and that both access and disclosure must be restricted. All staff are responsible for ensuring that:

Any personal data which is held is kept securely
Personal information is not disclosed either orally or in writing or otherwise to any unauthorised third party.

Rights to Access Information

All Data Subjects whose data is held by BCRU have the right to access any personal data that is being kept about them on computer and also have access to paper-based data held in certain manual filing systems. This right is subject to certain exemptions which are set out in the Data Protection Act. Any person who wishes to exercise this right should make the request in writing to the BCRU’s Information Compliance Manager.

The BCRU reserves the right to charge for each subject access request. If personal details are inaccurate, they can be amended upon request. The BCRU aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 40 days of receipt of a request unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual making the request. A fee will be payable.

BCRU is a wholly owned subsidiary of 4bi