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We regard
the lawful and correct treatment of personal information by the College as
very important to successful operations and for maintaining confidence
between ourselves and those with whom we deal. We therefore make every
effort to ensure that personal information is treated lawfully and
correctly.
Henley Management College needs to collect a range
of personal information in order to operate. This includes current, past
and prospective employees, suppliers, clients/customers, and others with
whom it communicates. The College requires this information to support the
administration of contracts with these people and, in addition, it may
occasionally be required by law to collect and use information of this
kind to comply with the requirements of government departments for
business data, for example. This personal information must be dealt with
properly however it is collected, recorded and used - whether on paper, in
a computer, or recorded on other material - and there are safeguards to
ensure this in the Data Protection Act 1998.
We fully endorse and
adhere to the Principles of data protection, as detailed in the Data
Protection Act 1998.
Specifically, the Principles require that
personal information:
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a) |
shall be processed fairly
and lawfully and, in particular, shall not be processed unless
specific conditions are met; |
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b) |
shall be obtained only for one or more specified and
lawful purposes, and shall not be further processed in any manner
incompatible with that purpose or those purposes; |
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c) |
shall be adequate, relevant and not excessive in
relation to the purpose or purposes for which they are
processed; |
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d) |
shall be accurate and, where necessary, kept up to
date; |
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e) |
shall not be kept for longer than is necessary for
that purpose or those purposes; |
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f) |
shall be processed in accordance with the rights of
data subjects under the Act; |
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g) |
shall not be transferred to a country or territory
outside the European Economic area unless that country or territory
ensures an adequate level of protection for the rights and freedoms
of data subjects in relation to the processing of personal data. The
European Economic Area comprises of the following countries:
Austria, Belgium, Cyprus, Czech Republic, Denmark, Estonia, Finland,
France, Germany, Greece, Holland, Hungary, Ireland, Italy, Latvia,
Lithuania, Luxembourg, Malta, Poland, Portugal, Slovak, Slovenia,
Spain, Sweden, United Kingdom.
and that: |
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h) |
appropriate technical and organisational measures
shall be taken against unauthorised or unlawful processing of
personal data and against accidental loss or destruction of, or
damage to, personal data; |
Therefore, Henley
Management College will, through appropriate management, and application
of criteria and controls:
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observe fully conditions
regarding the fair collection and use of information:
meet its
legal obligations to specify the purposes for which information is
used;
collect and process appropriate information, and only to
the extent that it is needed to fulfil operational needs or to
comply with any legal requirements; |
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ensure the quality of information used;
apply
strict checks to determine the length of time the information is
held; |
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ensure that the rights of people about whom
information is held can be fully exercised under the Act. (These
include: the right to be informed that processing is being
undertaken: the right of access to one’s personal information; the
right to prevent processing in certain circumstances; the right to
correct, rectify, block or erase information which is regarded as
the wrong information.); |
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take appropriate technical and organisational
security measures to safeguard personal information; |
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ensure that personal information is not transferred
abroad without suitable safeguards. |
In
addition, Henley Management College will ensure that:
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there is someone with
specific responsibility for data protection in the organisation (the
Data Protection Officer); |
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everyone managing and handling personal information
understands that they are contractually responsible for following
good data protection practice; |
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everyone managing and handling personal information
is appropriately trained to do so; |
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any third party organisation that processes data on
our behalf has adequate measures in place and provides us with
written guarantees to this effect; |
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queries about handling personal information are
promptly and courteously dealt with; |
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methods of handling personal information are clearly
described; |
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a regular review and assessment is made of the way
personal information is managed; |
Anybody
wanting to make enquiries about handling personal information should
contact the Data Protection Officer or the Personnel Office in the first
instance.
The College expects all employees with access to personal
information to respect the need for confidentiality and to avoid improper
use or transfer of such information. Any employee who fails to adhere to
these principles may be subject to disciplinary action.
November
2004
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