LSUK Data Protection Policy

Definitions

Company means LSUK, a registered Company.
GDPR means the General Data Protection Regulation.
Responsible Person means Imran Shah
Register Systems means a register of all systems or contexts in which personal data is processed by the Company.

Background

Language Services UK Limited (Hereafter referred to as: LSUK) is fully committed to comply and follow The Data Protectio Act 2018, which is the primary piece of legislation that controls how personal information is used by organisations, businesses or the government in Great Britain. The Data Protection Act 2018 states that everyone responsible for using personal data has to follow strict rules called ‘data protection principles’. They must make sure the information is:

  • used fairly, lawfully and transparently
  • used for specified, explicit purposes
  • used in a way that is adequate, relevant and limited to only what is necessary
  • accurate and, where necessary, kept up to date
  • kept for no longer than is necessary
  • handled in a way that ensures appropriate security, including protection against unlawful or unauthorised processing, access, loss, destruction or damage

There is stronger legal protection for more sensitive information, such as:

  • Race
  • Ethnic background
  • Political opinions
  • Religious beliefs
  • Trade union membership
  • Genetics
  • Biometrics (where used for identification)
  • Health
  • Sex life or orientation

There are separate safeguards for personal data relating to criminal convictions and offences.

Data protection principles

LSUK is committed to processing data in accordance with its responsibilities under the GDPR.

LSUK is fully committed to Article "5" of the GDPR requires that personal data shall be:
  • “Processed lawfully, fairly and in a transparent manner in relation to individuals;
  • Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  • Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  • Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  • Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals;
  • Processed in a manner that ensures appropriate security of the personal data,including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

General provisions

  • This policy applies to all personal data processed by LSUK.
  • The Responsible Person shall take responsibility for LSUK’s ongoing compliance with this policy.
  • This policy shall be reviewed at least annually
  • LSUK is registered with the Information Commissioner’s Office as an organisation that processes personal data. ( Registeration reference: xxxxxx)

Lawful, fair and transparent processing

  • To ensure its processing of data is lawful, fair and transparent, LSUK are maintaining a Register of Systems.
  • The Register of Systems shall be reviewed at least annually.
  • Individuals have the right to access their personal data and any such requests made to LSUK shall be dealt with in a timely manner.

Lawful purposes

a. All data processed by LSUK are done on one of the following lawful bases:

  • Consent
  • Contract,
  • Legal obligation,
  • Vital interests,
  • Public task
  • Any legitimate interests
  • LSUK will note the appropriate lawful basis in the Register of Systems.
  • Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent is kept with the personal data.
  • Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent is made clearly available by LSUK and systems are in place to ensure such revocation is reflected accurately in the LSUK systems.

Data minimisation

  • LSUK willl ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Accuracy

  • LSUK shall take reasonable steps to ensure personal data is accurate.
  • Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

Archiving / removal

  • To ensure that personal data is kept for no longer than necessary, LSUK has archiving policy and personal data is processed and reviewed annually.
  • The archiving policy shall consider what data should/must be retained, for how long, and why.

Security

  • LSUK ensures that personal data is stored securely using modern software that is kept-up-to-date
  • Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
  • When personal data is deleted this should be done safely such that the data is irrecoverable.
  • Appropriate back-up and disaster recovery solutions shall be in place.

Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, LSUK shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Inormation Commissioner’s Office.