Data Protection and Privacy Policy
Bright Harbour Ltd
1-2 Rhodium Point Hawkinge Business Park, Spindle Close, Hawkinge, Folkestone, Kent, United Kingdom, CT18 7TQ
caitlin.connors@brightharbour.co.uk
Last updated July 1st 2021
Bright Harbour Research Ltd needs to gather and use certain information about individuals. These may include end/service users, suppliers, contacts, members/employees, websites and applications’ users and other people the company 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 company’s data protection standards — and to comply with the law.
This data protection policy ensures Bright Harbour Research Ltd:
Complies with data protection law and follow good practice
Protects the rights of workers, customers, products’ users and partners
Is open about how it stores and processes individuals’ data
Protects itself from the risks of a data breach.
The Data Protection Act 1998 describes how organisations — including Bright Harbour Research Ltd — must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. The Data Protection Act is underpinned by eight important principles. These say that personal data must:
Be processed fairly and lawfully
Be obtained only for specific, lawful purposes
Be adequate, relevant and not excessive
Be accurate and kept up to date
Not be held for any longer than necessary
Processed in accordance with the rights of data subjects
Be protected in appropriate ways
Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, risks and responsibilities
This policy applies to:
Directors of Bright Harbour Research Ltd.
All employees and volunteers of Bright Harbour Research Ltd
All contractors, suppliers and other people working on behalf of Bright Harbour Research Ltd It applies to all data that the company holds relating to identifiable individuals (clients or members of the public), even if that information technically falls outside of the Data Protection Act 1998. This can include:
○ Names of individuals
○ Postal addresses
○ Email addresses
○ Telephone numbers
○ Any other information relating to individuals obtained in research screener data (e.g. behaviour, attitudes, demographics, etc).
Data protection risks
This policy helps to protect Bright Harbour Research Ltd from some very real data security risks, including:
Breaches of confidentiality. For instance, information being given out inappropriately.
Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Responsibilities
Everyone who works for or with Bright Harbour Research Ltd 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 principles. However, these people have key areas of responsibility:
The board of directors is ultimately responsible for ensuring that Bright Harbour Research Ltd meets its legal obligations.
The board of directors is also 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 schedule (yearly).
Arranging data protection training and advice for the 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 Bright Harbour Research Ltd holds about them (also called participant access requests’).
Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
The Founder, Caitlin Connors, is responsible for:
Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
Performing regular checks and scans to ensure security hardware and software is functioning properly.
Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
Monitoring access to any project materials stored on the Bright Harbour GDrive, and ensuring minimal permissions for any materials to be accessed only by people who directly require it for their work.
The board of directors is also responsible for:
Approving any data protection statements attached to communications such as emails and letters.
Addressing any data protection queries from journalists or media outlets like newspapers.
Where necessary, working with other staff or partners to ensure marketing initiatives abide by data protection principles
General staff and partner guidelines
The only people able to access data covered by this policy should be those who need it for their work. In particular, Personally Identifiable Data should be handled with additional care and should only be shared with staff and partners who have direct need for project work.
Data should not be shared informally. When access to confidential information is required, employees can request it from a company Director.
Bright Harbour Research Ltd will provide training to all employees to help them understand their responsibilities when handling data.
Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
In particular, strong passwords must be used and they should never be shared.
Personal data (e.g. participant screeners) should not be held on Cloud Computing folders (the Bright Harbour GDrive) without additional second layer encryption from BoxCrypt
Personal data should not be disclosed to unauthorised 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 a Bright Harbour Director if they have any queries about data protection.
Data storage
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller. When data is stored on paper, it should be kept in a secure place where unauthorised people 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, all paper copies are kept in a locked drawer or filing cabinet.
Employees and partners should make sure paper and printouts are not left where unauthorised 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 unauthorised access, accidental deletion and malicious hacking attempts, e.g. via:
All servers and computers containing data should be protected by approved security software and a firewall.
The use of additional encryption on cloud storage folders (Bright Harbour GDrive)
Password protection and secure file transfer for any materials including personally identifiable information (e.g. recruitment materials)
Monitoring of access rights for all cloud materials, ensuring minimal access for staff and partners who have direct need for access, and removal of all access rights beyond Bright Harbour staff upon project completion
Personally identifiable data should be minimised in all ways and all times possible. There should be only one file per project that links participant data with identifiable details like contact information, name, etc. In all other cases data is anonymised using participant numbers (e.g. Participant 1) and/or session details (Phase 1 Group July 1 2021).
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 an approved cloud computing services utilising additional encryption (Bright Harbour Google Drive account, BoxCrypt encryption).
Data should never be saved directly to laptops or other mobile devices like tablets or smart phones
Data use
Personal data is of no value to Bright Harbour Research Ltd 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 and partners should ensure the screens of their computers are always locked when left unattended
Personal data (including details like participant names, contact details, etc) should never be shared informally. In particular, it should never be sent by email, text or social media, as these forms of communication is not secure
Data must be encrypted and password protected before being transferred electronically.
Personal data should never be transferred outside of the European Economic Area; we do however use anonymised transcript software that functions outside of EEA, stripped from any identifying personal information. No software should be used for research data gathering that is not EEA located and GDPR compliant.
Data accuracy
The law requires Bright Harbour Research Ltd 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 Bright Harbour Research Ltd 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 and up to date as possible.
Data will be held in as few places as necessary. Staff and partners should not create any unnecessary additional data sets
Data should be updated as inaccuracies are discovered. For instance, if a participant declines to have their data included in research, their information would be deleted from the relevant recruitment profile sheet.
Subject access requests
All individuals who are the subject of personal data held by Bright Harbour Research Ltd 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 contacts the company requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email, addressed to the data controller at caitlin.connors@brightharbour.co.uk. The data controller can supply a standard request form, although individuals do not have to use this. 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 access request before handing over any information.
Disclosing data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances,
Bright Harbour Research Ltd 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 advisers where necessary.
Providing information
Bright Harbour Research Ltd 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
Consent forms contain full information about why data is gathered, how it is used, how it is stored, and participants’ right to refusal and right to be forgotten. They are welcome to read this data protection policy for more details on request.