Data Protection Policy
This policy has been prepared by: Zaria Sleith
This policy became operational on: 25th January 2020
Next review date: 25 July 2020
Zaria Sleith Photography needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.
Why this policy exists
This data protection policy ensures that Zaria Sleith Photography :
Complies with data protection law and follow good practice
Protects the rights of customers and partners
Is open about how it stores and processes individuals’ data
Protects itself from the risks of a data breach
Data protection law
The GDPR describes how organisations — including Zaria Sleith Photography — must collect, handle and store personal information.
These rules apply regardless of whether 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 GDPR is underpinned by eight important principles. These say that personal data must:
Be processed fairly and lawfully
Be obtained only for specific, lawful purposes
Be adequate, relevant and not excessive
Be accurate and kept up to date
Not be held for any longer than necessary
Processed in accordance with the rights of data subjects
Be protected in appropriate ways
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
This policy applies to:
The head office of Zaria Sleith Photography
All branches of Zaria Sleith Photography (also trading as Zemes Beauty Boutique, makeup products for models and brides)
All staff and volunteers of Zaria Sleith Photography
All contractors, suppliers and other people working on behalf of Zaria Sleith Photography
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:
Names of individuals
…plus any other information relating to individuals (such as wedding date)
Data protection risks
This policy helps to protect Zaria Sleith Photography from some very real data security risks, including:
Breaches of confidentiality. For instance, information being given out inappropriately.
Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with Zaria Sleith Photography has some responsibility for ensuring data is collected, stored and handled appropriately. Whomever at Zaria Sleith Photography 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:
Zaria Sleith is ultimately responsible for ensuring that Zaria Sleith Photography meets its legal obligations. Zaria Sleith is responsible for:
Keeping updated about data protection responsibilities, risks and issues.
Reviewing all data protection procedures and related policies, in line with an agreed schedule.
Arranging data protection training and advice for the people covered by this policy.
Handling data protection questions from staff and anyone else covered by this policy.
Dealing with requests from individuals to see the data Zaria Sleith Photography holds about them (also called ‘subject access requests’).
Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
Zaria Sleith is responsible for IT used at Zaria Sleith Photography , including computers, laptops, mobile phones and other devices that can store personal data. Zaria Sleith will ensure
that all systems, services and equipment used for storing data meet acceptable security standards.
Performing regular checks and scans to ensure security hardware and software is functioning properly.
Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
Zaria Sleith is responsible for any marketing related activities at Zaria Sleith Photography . Zaria is responsible for:
Approving any data protection statements attached to communications such as emails and letters.
Addressing any data protection queries from journalists or media outlets like newspapers.
Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
General guidelines for data usage
The only people able to access data covered by this policy should be those who need it for their work.
Data should not be shared informally. When access to confidential information is required, it can be request from Zaria Sleith.
Zaria Sleith Photography will request that suppliers understand their responsibilities when handling data.
In particular, strong passwords must be used and they should never be shared.
Personal data should not be disclosed to unauthorised people, either within the company or externally.
Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see or access it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
When not required, the paper or files should be kept in a locked drawer or filing cabinet. Zaria will make sure paper and printouts are not left where unauthorised people could see them, like on a printer. Data printouts should be shredded and disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
Data should be protected by strong passwords that are changed regularly and never shared between employees.
If data is stored on removable media (like a USB or external disk), these should be kept locked away securely when not being used.
Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
Servers containing personal data should be sited in a secure location, away from general office space.
Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Zaria Sleith Photography unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
When working with personal data, Zaria Sleith will ensure the screens of their computers are always locked when left unattended.
Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
Data must be encrypted before being transferred electronically.
Personal data should never be transferred outside of the European Economic Area.
Only central copies of any data will accessed and updates. There must not be multiple copies of personal data.
The law requires Zaria Sleith Photography to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort Zaria Sleith Photography should put into ensuring its accuracy. Zaria Sleith is take reasonable steps to ensure it is kept as accurate and up to date as possible.
Data will be held in as few places as necessary. Zaria Sleith should not create any unnecessary additional data sets. Zaria Sleith should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call. Zaria Sleith Photography will make it easy for data subjects to update the information Zaria Sleith Photography holds about them. For instance, via the company website. 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. It is the Zaria Sleith’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject access requests
All individuals who are the subject of personal data held by Zaria Sleith Photography are entitled to:
Ask what information the company holds about them and why.
Ask how to gain access to it.
Be informed how to keep it up to date.
Be informed how the company is meeting its data protection obligations.
If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, using the below contact form. Enquiries sent through this form are sent directly Zaria Sleith. You can also call Zaria Sleith directly at 07855086515.
Individuals will be charged £10 per subject access request. Zaria Sleith will aim to provide the relevant data within 14 days.
Zaria Sleith 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 GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Zaria Sleith Photography will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Zaria Sleith Photography aims to ensure that individuals are aware that their data is being processed, and that they understand:
How the data is being used
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.
My website's cookies policy
What are cookies?
Sometimes cookies remember what you were looking at and at that point they can help provide the website with information about what kind of product you last looked at and it will offer you similar or related things.
So what information does a cookie collect?
Cookies in general collect details about the pages you are looking at when you access a website via the same computer or device. This includes information about the pages you viewed, and the trail of pages you have looked at within one website.
What I don't do on my website is collect or record information on your name, address or other contact details. My cookies are only here to monitor your browsing behaviour so that I can see if my website is working, if I deliver the correct information to my existing and potential clients.
Where do the cookies come from?
The cookies that are stored on your computer or other device when you access my websites are designed by:
the company I have my website hosted with (Webflow)
third parties who I have linked in with, such as Google Analytics, Instagram, Facebook.
The Facebook Pixel is also implemented on my website.
What I do with Google Analytics
I use Google Analytics software on my website to collect information about how you use my website. I do this to help make sure that my website site is meeting the needs of my existing and potentially new clients and it also helps me to make continuous improvements to my website.
Google Analytics stores information about:
the pages you visit on
how long you spend on each page
how you got to the site (i.e. have you found my website on a search engine, or have you clicked on a link on another website, such as a blog for example)
what you click on while you’re visiting my website
I do not collect or store your personal information (for example your first or last name or address). So none of this information can be used to identify who you are when you visit my website.
I have also enabled IP address anonymisation so that my website users’ IP addresses are not transmitted to Google. You can read about this here.
What are cookies used for?
The main purposes for which cookies are used mainly are:
technical reasons that allow me to run my website, particularly in relation to website site navigation.
in order to gather information about my visitor numbers, their browsing patterns, length of time you have been on my website and so on.
Can I disable cookies?
If you want to disable cookies on your computer or device, you need to change your website browser settings to no longer allow cookies to be placed. Because there are many different browsers out there, they all work differently. So please check your own browser, and then you can search online for something like "How to disable cookies in Internet Explorer" (and then replace the words "Internet Explorer" with the browser you are using, such as Firefox, Chrome, Safari, Opera etc.).
Does anything happen when you disable cookies?
This depends on which cookies you disable. Generally, this might prevent many websites from operating normally and you might see error messages or jumbled up pages when the cookies are not enabled. There is also an option to switch off Third Party Cookies only which for most websites will not have any effect on them working correctly. If you disable all cookies, you might be unable to see some pages on my website.