It is necessary for Blue Sky Global Solutions Limited (Blue Sky) to gather and use relevant information about individuals.
These can include customers, suppliers, business contacts, employees and other people the organisation 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 Blue Sky Global Solutions Limited:
Blue Sky Global Solutions Limited is committed to a policy of protecting the rights and privacy of individuals, including learners, staff and others, in accordance with the General Data Protection Regulation (GDPR) May 2018. 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:
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 be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an
adequate level of protection
This piece of legislation comes in to force on the 25th May 2018. The GDPR regulates the processing of personal data, and protects the rights and privacy of all living individuals including children), for example by giving all individuals who are the subject of personal data a general right of access to the personal data which relates to them. Individuals can exercise the right to gain access to their information by means of a ‘subject access request’. Personal data is information relating to an individual and may be in hard or soft copy (paper/manual files; electronic records; photographs; CCTV images), and may include facts or opinions about a person.
For more detailed information on these Regulations see the Data Protection Data Sharing Code of Practice (DPCoP) from the Information Commissioner’s Office (ICO).
This policy applies to:
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act. This can include:
This policy helps to protect Blue Sky from some very real data security risks, including:
Everyone who works for or with Blue Sky Global Solutions Limited 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
However, these people have key areas of responsibility:
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 data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious
Personal data is of no value to Blue Sky 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:
The law requires Blue Sky 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 Blue Sky 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.
All individuals who are the subject of personal data held by Blue Sky are entitled to:
If an individual contact 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 Jo Lara at
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.
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, Blue Sky Global Solutions Limited 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.
Blue Sky publishes various items which will include some personal data (e.g. internal telephone directory, photos and information in marketing materials).
It may be that in some circumstances an individual wishes their data processed for such reasons to be kept confidential or restricted to Blue Sky access only. Therefore, it is Blue Sky policy to offer an opportunity to opt-out of the publication of such when collecting the information.
It is the policy of Blue Sky to ensure that senders and recipients of email are made aware that under the DPA, and
Freedom of Information Legislation, the contents of email may have to be disclosed in response to a request for
information. One means by which this will be communicated will be by a disclaimer on the Blue Sky email.
Under the Regulation of Investigatory Powers Act 2000, Lawful Business Practice Regulations, any email sent to or from the Blue Sky may be accessed by someone other than the recipient for system management and security purposes.
There are CCTV systems operating within Blue Sky for the purpose of protecting Staff and property. Blue Sky will only process personal data obtained by the CCTV system in a manner which ensures compliance with the legislation.
Blue Sky aims to ensure that individuals are aware that their data is being processed, and that they understand:
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.
This is available on request.
This policy will be updated as necessary to reflect best practice or future amendments made to the General Data
Protection Regulation (GDPR) May 2018 and Data Protection Act 1998.
Please follow this link to the ICO’s website (www.ico.gov.uk) which provides further detailed guidance on a range of topics including individuals’ rights, exemptions from the Act, dealing with subject access requests, how to handle requests from third parties for personal data to be disclosed etc. In particular, you may find it helpful to read the Guide to Data Protection which is available from the website. For help or advice on any data protection or freedom of information issues, please do not hesitate to contact: The Data Protection Officer (DPO).
A person who (either alone or jointly or in common with other persons) determines the purposes for which and the
manner in which any personal data are, or are to be, processed. The term comprises not only individuals but also
organisations such as companies and other corporate bodies of persons.
Any person (other than an employee of the data controller) who processes the data on behalf of the data controller.
Any living individual who is the subject of personal data.
Information which relates to a living individual who can be identified from that data, from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.
Any operation or set of operations performed upon personal data, whether or not by automatic means. These include
collecting, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
Personal data which consists of data related to the data subject’s racial or ethnic origin political opinions, religious or
similar beliefs, trade union membership, physical or mental health, sexual life, the commission of offences or criminal proceedings.
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