Policy Prepared by: Pauline Gray
Policy Prepared on: 08/03/2018
Next Review date: 08/03/2019
As a model agency Model Students processes personal data in relation to its own staff, models/work-seekers and individual client contacts. It is vitally important that we abide by the principles of the Data Protection Act 1998 set out below.
Model Students holds data on individuals for the following general purposes:
- Staff Administration
- Advertising, marketing and public relations
- Accounts and records
- Administration and processing of models/work-seekers personal data for the purposes of work-finding services
Data Protection Law
The Data Protection Act 1998 requires Model Students act as data controller to process data in accordance with the principles of data protection. These require that data shall be:
- Fairly and lawfully processed
- Processed for limited purposes
- Adequate, relevant and not excessive
- Not kept longer than necessary
- Processed in accordance with the staff, model/work seekers data rights
- Kept securely
People Risk and Responsibilities
Personal data means data, which relates to a living individual who can be identified from the data or from the data together with other information, which is in the possession of, or is likely to come into possession of, Model Students.
Processing means obtaining, recording or holding the data or carrying out any operation or set of operations on the data. It includes organising, adapting and amending the data, retrieval, consultation and use of the data, disclosing and erasure or destruction of the data. It is difficult to envisage any activity involving data, which does not amount to processing. It applies to any processing that is carried out on computer including any type of computer however described, desktop, laptop etc.
Data should be reviewed on a regular basis to ensure that it is accurate, relevant and up to date and all Model Student staff shall be responsible for doing this.
Data may only be processed with the consent of the person whose data is held. Therefore, if they have not consented to their personal details being passed to a third party doing so may constitute a breach of the Data Protection Act 1998.
By instructing Model Students to look for work and providing us with personal data contained in a CV or Model Details Form the model or work-seekers will be giving their consent to processing their details for work-finding purposes. If you intend to use their data for any other purpose you must obtain their specific consent. However, caution should be exercised before forwarding personal details of any of the individuals on which data is held to any third party such as past, current or prospective employers, suppliers, customers and clients, persons making an enquiry or complaint and any other third party.
General Staff Guidelines
All staff are permitted to add, amend, or delete data from the database and amend where information is known to be old, inaccurate or out of date. In addition, all employees should ensure that adequate security measures are in place. For example:
- Computer screens should not be left open by individuals who have access to personal data
- Passwords should not be disclosed
- Email should be used with care
- Personnel files and other personal data should be stored in a place in which any unauthorised attempts to access them will be noticed. They should not be removed from their usual place of storage without good reason
- Personnel files should always be locked away when not in use and when in use should not be left unattended
- Any breaches of security should be treated as a disciplinary issue
- Care should be taken when sending personal data in internal or external mail
- Destroying or disposing of personal data counts as processing. Therefore, care should be taken in the disposal of any personal data to ensure that it is appropriate. For example, it is necessary to shred sensitive data rather than merely to dispose of it in the dustbin.
It should be remembered that the incorrect processing of personal data e.g. sending an individual’s details to the wrong person; allowing unauthorised person access to personal data; or sending information out for purposes for which the individual did not give their consent, may give rise to a breach of contract and/or negligence leading to a claim against Model Students for damages from an employee, work-seeker or client contact. A failure to observe the contents of this policy will be treated as a disciplinary offence.
Data Protection Officer
All requests to access data by staff, models/work seekers, customers or clients etc. should be referred to Pauline Gray (Data Protection Officer) email: firstname.lastname@example.org
Any requests for a reference by a third party must be referred to Pauline Gray and should be treated with caution.