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Statement of Intent

As part of its need to deliver services to its customers, Tapiochre needs to gather and use certain information about individuals within that customer base. This information can include customer names, supplier names, business contacts, employees and other people that we have a relationship with or who we may need to contact. This policy describes how his personal data must be collected, handled and stored to meet our data protection standards and to comply with the law.

Why this policy exists

This data protection policy ensures that Tapiochre:

a. complies with data protection law and follows good practice

b. acts only with the explicit instructions of our customer (you)

c. has appropriate technical and organisational security

d. protects the rights of staff, customers and partners

e. is open about how it stores and processes individuals’ data

f. protects itself from the risks of data breach

g. focuses on the expectations of the 2018 EU General Data Protection Regulation in how we act as a data processor (service provider) and also as a data controller.

Tapiochre as Data Controller and Data Processor

Information Commissioner's Office (ICO) have defined roles and responsibilities for Data Controllers and Data Processors.

  1. With reference to the state of being a Data Controller
    1. Tapiochre Ltd is the Data Controller for those processes necessary for performing its own business.
    2. In this respect we collect, handle and store (i.e 'Process') data about individuals in order to run our business.
  2. With reference to the state of being a Data Processor
    1. Tapiochre Ltd is a Data Processor for our customer who use our services
    2. In this respect the Data Controller within out customer's environment will instruct, by email, that we process data sent to us for addition or removal from their website. Such instructions are explicit. Tapiochre never performs any action in relation to a customer website which is associated with individial person's data without express instruction.

In all cases, under the GDPR, we have a general obligation to implement technical and organisational measures to show that we have considered and have integrated data protection into our processing activities. This approach is termed "Privacy by Design" and the ICO has published guidance on privacy by design, which is an evolving document to support business in this area. Although this approach is not a requirement of the Data Protection Act, it helps us to comply with our obligations under the legislation.

Data protection law

The Data Protection Act 1998 describes how organisations, including Tapiochre Ltd, must collect, handle and store personal information. These rules apply regardless of whether the 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 state that personal data must:

a. be processed fairly and lawfully

b. be obtained only for specific law purposes

c. be adequate, relevant and not excessive

d. not be held for any longer than necessary

e. be processed in accordance with the rights of data subjects

f. be protected in appropriate ways

g. 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

Policy Scope

This policy applies to

a. the head office of Tapiochre Ltd

b. all staff and any volunteers of Tapiochre Ltd

c. all contractors, suppliers and other people working on behalf of Tapiochre Ltd

It applies to all data which Tapiochre Ltd holds relating to identifiable individuals, even if the information technically falls outside of the Data Protection Act 1998. This can include:

a. Names of individuals

b. Postal addresses

c. E-mail addresses

d. Telephone numbers

e. Any other information relating to individuals which can be used to identify them uniquely.

Data protection risks

This policy helps to protect Tapiochre Ltd from some very real data security risks, including:

a. Breaches of confidentiality. For instance, information being given out or shared inappropriately.

b. Failing to offer choice. For instance, all individuals should be free to choose how Tapiochre Ltd uses data relating to them.

c. Reputational damage. For instance, Tapiochre Ltd could suffer if hackers successfully gained access to sensitive data.


Everyone who works for, or with Tapiochre Ltd has some responsibility for ensuring data is collected, stored and handled appropriately.

Each person or 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:

a. The board of directors is ultimately responsible for ensuring that Tapiochre Ltd meets its legal obligations

b. The managing director, Chris Elliott is responsible for:

a. Keeping the board updated about data protection responsibilities, risks and issues.

b. Reviewing all data protection procedures and related policies, in line with an agreed schedule.

c. Arranging data protection training and advice for the people covered by this policy.

d. Handling data protection questions from staff and anyone else covered by this policy.

e. Dealing with requests from individuals to see the data which Tapiochre Ltd holds about them - this is also called ‘Subject Access Requests’.

f. Checking and approving any contracts or agreements with third parties that may handle Tapiochre Ltd’s sensitive data.

g. Ensuring that all systems, services and equipment used to store data meet acceptable security standards.

h. Performing regular checks and scans to ensure security hardware and software is functioning properly.

i. Evaluating any third-party services that Tapiochre Ltd is considering using to store or process data. For instance, cloud computing service providers.

j. Approving any data protection statements attached to communications such as e-mails and letters.

k. Addressing any data protection queries from journalists or media outlets such as newspapers.

l. Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General guidelines for staff employed by Tapiochre Ltd

a. The only people able to access data covered by this policy should be those who need it for their work

b. Data should not be shared informally. When access to confidential information is required, employees must request it from the managing director.

c. Tapiochre Ltd will provide training to employees to help them understand their responsibilities when handling data.

d. Employees should keep all data secure, taking sensible precautions and following the guidelines outlined in this policy.

e. In particular, strong passwords must be used and they should never be shared.

f. Personal data should not be disclosed to unauthorised people, either within the company or externally.

g. Data should be reviewed regularly and updated if it is found to be out of date. If the data is no longer required, it should be deleted and be disposed of.

h. Employees should request help from their managing director if they are unsure about any aspect of 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 managing director.

When data is stored on paper, it should be kept in a secure place, so that unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically and which has been printed out for a specific reason:

a. When not required, the paper or file should be kept in a locked drawer filing cabinet.

b. Employees should make sure that paper copies and printouts are not left where unauthorised people could see them, such as on the printer.

c. Data printouts should be shredded and disposed of securely where no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

a. Data should be protected by strong passwords that are changed regularly and never shared between employees.

b. If the data is stored on removable media, such as CD, DVD, USB memory stick, then they should be kept locked away securely when not being used.

c. Data should all be stored on designated driver and servers, and should only be uploaded to an approved cloud computing service.

d. Services containing personal data should be sited in a secure location, away from general office space.

e. Data should be backed up frequently. Those backups should be tested regularly, in line with the company's standard backup procedures.

f. Data should never be sent directly to laptops or other mobile phones such as tablets or smart phones.

g. All servers and computers containing data should be protected by approved security software and a firewall.

Data Use

Personal data is of no value to Tapiochre Ltd unless the business can make use of it. However we are aware that it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption of theft.

a. Working with personal data, employees should ensure the screens of their computers are always locked when left unattended.

b. Personal data should not be shared informally. In particular, it should never be sent by e-mail, as this form of communication is insecure.

c. Data must be encrypted before being transferred electronically. The managing director can explain how to send data in this way.

d. Personal data should never be transferred outside of the EEA.

e. Employees should not save copies of personal data to their own computers. Always access and update central copies of data.

Data Accuracy

The law requires Tapiochre Ltd to take reasonable steps to ensure that data is kept accurate and up-to-date.

a. The more important it is that the personal data is accurate, then the greater the effort Tapiochre Ltd put into ensuring its accuracy.

b. 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.

c. Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.

d. Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.

e. Tapiochre Ltd will make it easy for data subjects to update the information Tapiochre Ltd holds about them. For instance, via contact form on the company website, by e-mail or by telephone.

f. Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.

Subject access requests

All individuals who are the subject of personal data held by Tapiochre Ltd are entitled to:

a. Ask what information Tapiochre Ltd holds about them and why.

b. Ask how to gain access to it.

c. Be informed how to keep it up to date.

d. Be informed how Tapiochre Ltd is meeting its data protection obligations.

If an individual contacts Tapiochre Ltd requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the managing director at This email address is being protected from spambots. You need JavaScript enabled to view it..

The managing director will supply a standard request form, although individuals do not have to use this.

Individuals will be not be charged for serving subject access requests. The managing director will aim to provide the relevant data within 14 days.

The managing director 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, Tapiochre Ltd will disclose requested data. However, the managing director will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing information

Tapiochre Ltd aims to ensure that individuals are aware that their data is being processed, and that they understand:

a. How the data is being used

b. How to exercise their rights

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. A version of this statement is also available on the company’s website.


There are currently no addenda to this agreement.

Policy Date and Status

This policy has been updated to take full account of the GDPR.

Date: 11 January 2018