Privacy Policy

1.00 introduction.

The GDPR came into effect in the United Kingdom on 25th May 2018. The GDPR introduces a number of new obligations on Data Controllers and Data Processors and new rights for Data Subjects.

2.00 purpose.

BJP is committed to transparency in its collection and use of the Personal Data of its Customers, Design Team Members, Suppliers and Employees and to meeting its Data protections obligations pursuant to the GDPR. This Policy sets out BJP’s commitment to Data Protection and Data Subject rights in relation to Personal Data.

3.00 scope and effective date.

This Policy is in addition to BJP’s Employee Protection Policy & Procedure relevant to Employees.
The effective date of this policy is 25th May 2018.

4.00 person with responsibility for data protection. 

The Mechanical Director of BJP Consulting Group Limited is the person with the primary responsibility for Data Protection Compliance within the Practice.

5.00  policy.

5.01  definition of terms

BJP
BJP Consulting Group Limited is a Company registered in England and Wales and whose registered office is at The Well House, Manor Courtyard, Stratton-on-the-Fosse, Bath, BA3 4QF.

Data Controller
BJP Representative who determines the purposes for which and the manner in which any Personal Data is, or is to be, processed

Data Subject
The individual to which the Personal Data refers

Employee
Any job applicant or candidate, full or part time; temporary or permanent employee, apprentice and former employee of BJP

GDPR
The General Data Protection Regulation (EU) 2016/679

Personal Data
Any information that relates to a living individual who can be identified from that information

Processing
Any use that is made of data including collecting, storing, amending, disclosing or destroying it

5.02  data protection principles

BJP processes Personal Data in accordance with the GDPR and the following data protection principles.

(a)  BJP processes Personal Data lawfully, fairly and in a transparent manner;

(b)  BJP collects Personal Data on for specified, explicit and legitimate purposes;

(c)  BJP processes Personal Data only where it is adequate, relevant and limited to what is necessary for the purposes of processing;

(d)  BJP keeps accurate Personal Data and takes all reasonable steps to ensure that inaccurate Personal Data is rectified or deleted without delay;

(e)  BJP keeps Personal Data only for the period necessary for processing;

(f)  BJP adopts appropriate measures to make sure that Personal Data is secure and protected against unauthorised or unlawful processing, accidental loss or destruction.

5.03  privacy notices and privacy statement

BJP informs Data Subjects the reasons for processing their Personal Data, how it uses such data and the legal basis for processing in its privacy notices. In addition to any specific privacy notices that may be contained in BJP’s terms of business or other online or paper forms.

Main reasons for collecting/processing data include:

  • Entering into business contracts, providing fee proposals, terms and conditions, issuing invoices and all legal obligations such as health and safety matters.

  • In addition, BJP has a legitimate interest in processing personal data, allowing us to:

  • Inform clients on key information regarding a project;

  • Inform all third parties of business changes that may affect them;

  • Respond to any queries and complaints;
    Maintain accurate and up-to-date supplier, design team and client contact

    details

  • Invitation to Annual Open Day

  • Emergency contact details

Human Resources including Salary payments

BJP will not process Personal Data of Data Subjects for other reasons. Where BJP relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure those interests are not overridden by the rights and freedoms of Data Subjects.

BJP will update Personal Data promptly if Data Subject advises that his/her information has changed or is inaccurate.

BJP keeps a record of its processing activities in respect of Personal Data in accordance with the requirements of the GDPR.

5.04  individual rights

Data Subjects have a number of rights in relation to their Personal Data.

5.05  subject access requests

Data Subjects have the right to make a Subject Access Request (“SAR”). If an individual makes a SAR, BJP will tell him/her:

  1. Whether or not his/her data is processed and if so why, the categories of Personal Data concerned and the source of the data if it is not collected from the individual;

  2. To whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that will apply to such transfers;

  3. For how long his/her Personal Data is stored (or how that period is decided);

  4. His/her rights to rectification of erasure of Personal Data, or to restrict or object to processing;

  5. His/her right to complain if he/she thinks BJP has failed to comply with his/her data protection rights; and

  6. Whether or not BJP carried out automated decision making and the logic involved in such decision making.

BJP will also provide the individual with a copy of the Personal Data undergoing processing unless there is some lawful basis for not doing so, in which case it will inform the Data Subject of the reasons for this.

Any data provided will normally be in electronic form if the Data Subject has made a request electronically, unless he/she agrees otherwise or it is otherwise not technically possible or practicable for BJP to provide it electronically.

To make an SAR, the Data Subject should send the request to jonathan.cooper@bjp-uk.com or as a written letter to Mr J Cooper, Mechanical Director, BJP Consulting Group Limited, The Well House, Manor Courtyard, Stratton-on-the-Fosse, Bath, BA3 4QF.

BJP will normally respond to a request within one month from the date it is received.

If a SAR is manifestly unfounded or excessive, BJP is not obliged to comply with it. Alternatively, BJP can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which BJP has already responded. If a Data Subject submits a request that is unfounded or excessive, BJP will notify him/her that this is the case and whether or not BJP will respond to it.

5.06 other rights

Data Subjects have a number of other rights in relation to their Personal Data. They can require a Data Controller to:

  1. Rectify inaccurate data;

  2. Stop processing or erase data that is no longer necessary for the purposes of processing;

  3. Stop processing or erase data if the Data Subject’s interests override the BJP Representative’s legitimate grounds for processing data (where the BJP Representative’s relies on its legitimate interests as a reason for processing data);

  4. Stop processing or erase data if processing is unlawful; and

  5. Stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the Data Subject’s interests override the BJP Representative’s legitimate grounds for processing data.

To ask BJP to take any of these steps, the Data Subject should send the request to jonathan.cooper@bjp-uk.com or by letter to Mr Jonathan Cooper, Mechanical Director, BJP Consulting Group Limited, The Well House, Manor Courtyard, Stratton-on-the-Fosse, Bath, BA3 4QF.

5.07 data security

BJP takes the security of Personal Data seriously. BJP has internal policies and controls in place to protect Personal Data against loss, accidental destruction, misuse or disclosure and to ensure that data is not accessed, except by Employees in the proper performance of their duties.

BJP requires all its Employees to follow its IT Security Policy, Information Security Policy and Data Breach Policy.

5.08  privacy impact assessments

Some of the processing that BJP carries out may result in risks to privacy. Where processing would result in a high risk to a Data Subject’s rights and freedoms, BJP will carry out a data protection privacy impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risk for Data Subjects and the measures that can be put in place to mitigate those risks.

5.09  data breaches

If BJP discovers that there has been a breach of Personal Data that poses a risk to the rights and freedom of Data Subjects, it will report it to the Information Commissioner’s Office within 72 hours of discovery. BJP will record all data breaches regardless of their effect.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will inform affected individuals that there has been a breach and provide them with the information about its likely consequences and the mitigation measures it has taken.

If employees suspect or become aware of a data security breach they are required to follow the steps set out in our Personal Data Breach Policy to enable BJP to respond appropriately.

5.10  individual responsibilities

Data Subjects are responsible for helping BJP to keep their personal Data up to date. Data Subjects should let BJP know if data provided to BJP changes.

BJP’s Employees may have access to the Personal Data of its customers, design teams and suppliers in the course of their employment, contract or apprenticeship.

Where this is the case, BJP relies on its Employees to meet its data protection obligations to those Customers, Suppliers and Members of Design Teams.

Employees who have access to Personal Data are required:

  1. to access only data that they have authority to access and only for authorised purposes;

  2. not to disclose data except to individuals (whether inside or outside the organisation) who have appropriate authorisation;

  3. to keep data secure (for example by complying with rules on access to premises, computer access, including password protection and secure file storage and destruction);

  4. not to remove personal Data, or devices containing or that can be used to access Personal Data, from BJP’s premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device;

  5. not to store Personal Data on local drives or on personal devices that are used for work purposes; and

  6. to report data breaches of which they become aware to the Mechanical Director immediately in accordance with BJP’s Personal Data Breach Policy.

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under BJP’s disciplinary procedure. Significant or deliberate breaches of this policy, such that accessing Employee, Customer, Supplier data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.

5.11 training

BJP will provide appropriate training to relevant employees about their data protection responsibilities as part of the induction process and at regular intervals thereafter.

Employees whose roles require regular access to Personal Data, or who are responsible for implementing this Policy or responding to SARs in this Policy will receive additional training to help them understand their duties and how to comply with them.

6.00 review of this policy

BJP will review this Policy periodically and will make any required updates.

7.00 further information and support.

In the event of further queries about this Policy, please contact jonathan.cooper@bjp-uk.com or by letter to Mr Jonathan Cooper, Mechanical Director, BJP Consulting Group Limited, the Well House, Manor Courtyard, Stratton-on-the-Fosse, Bath, BA3 4QF.