“Cornerstone Partners” (and “we”, “us”, or “our”) refers to Greenwood Partners LLP (the limited partnership registered in England under registration no. OC414259 and with its registration address at The Retreat 406 Roding Lane South Woodford Green Essex IG8 8EY) and such other Cornerstone Partners subsidiaries (including CP Nominee Limited) that is a party you contract with for providing or receiving services, or you have a role or relationship with. Each company in the Cornerstone Partners group is a separate legal entity and a separate controller for personal data. Under Article 4(7) of the GDPR, “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Cornerstone Partners needs to gather and use certain information about individuals. This can include customers, suppliers, business contacts, partners, interns, volunteers 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. This policy is exclusively for internal use.
Why this policy exists
This data protection policy ensures Cornerstone Partners:
- complies with data protection law and follow good practice;
- protects the rights of staff, customers and partners;
- is open about how it stores and processes individuals’ data; and
- protects itself from the risks of a data breach.
Legal Authority & Basis
The Data Protection Act 2018 is the governing law for this issue and it domesticates the EU GDPR and also updates the 1998 Data Protection Act. This legislation enancts the UK GDPR into UK law and covers extended data protection and privacy requirements specific to the UK. Members of Cornerstone Partners responsible for using personal data have to follow strict rules called “data protection principles”. They must make sure the information is:
- used fairly, lawfully and transparently;
- used for specified, explicit purposes;
- used in a way that is adequate, relevant and limited to only what is necessary;
- accurate and, where necessary, kept up to date;
- kept for no longer than is necessary;
- handled in a way that ensures appropriate security, including protection against unlawful or unauthorised processing, access, loss, destruction or damage; and
- restricted on data transfer especially when transferring to a receiver to which the GDPR does not apply i.e. outside the EEA.
This policy especially applies to all partners, interns, staff and volunteers of Cornerstone Partners and all contractors, suppliers and other people working on behalf of Cornerstone Partners.
It applies to all data that the company holds relating to identifiable individuals including but not limited to:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers and any other information relating to individuals including but not limited to national insurance numbers, bank account details, next of kin details, disciplinary records of which you are involved or initiate etc. You may have and continue to provide these details during your engagement with Cornerstone Partners. Some of this data may be in the public domain and some we source from a former employer for instance.
- Sickness records, copies of doctors’ notes and any information you make available to us in connection with your health and this can include dietary requirements (vegan) To inform your colleagues and others that your absence is authorised, as reasonably necessary to manage your absences, to inform reviewers for appraisal purposes of your sickness absence level
- We may monitor your use of IT systems including but not limited to email, internet and other communication or IT resources
- Performance reviews
Data protection risks
This policy helps to protect us from some very real data security risks, including:
- Breaches of confidentiality: information being given out inappropriately.
- Failing to offer choice: all individuals should be free to choose how the company uses data relating to them.
- Reputational damage: the company could suffer if hackers successfully gained access to sensitive data.
Kindly note the newly established role of Data Protection Officer under the GDPR
The DPO facilitates compliance and competitive advantage for businesses. In addition to facilitating compliance through the implementation of accountability tools (such as facilitating data protection impact assessments and carrying out or facilitating audits), DPOs act as intermediaries between relevant stakeholders.
The GDPR sets minimum responsibilities for a DPO that revolve around supervising the implementation of a data protection strategy, assuring compliance with GDPR, and other applicable data protection laws.
The DPO also oversees the data privacy and data protection policies to ensure the operationalization of those policies through all organizational units and makes sure we process personal data of data subjects (partners, interns, volunteers, customers, and other individuals) in a compliant way.
The DPO should operate independently, with full support from upper management and board, and have access to all needed resources to do the job according to best practices.
Most commonly, the DPO is an IT professional (Security) or an expert with a legal background, but this is not the rule. The DPO should also be a person who is familiar with the business and day to day operations that we conduct with an emphasis on data processing activities.
The DPO is not personally responsible for our GDPR compliance, it is always a controller (us) or the processor (a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller) who is required to demonstrate compliance. The controller (we) or the processor are obligated to provide all necessary tools, resources and personnel to enable the DPO to perform tasks.
We can choose and appoint a DPO among the existing partners or outsource the role to an external DPO. If we do not require a full-time DPO, we can appoint a DPO that can work half time as a DPO and half time in another role, provided that those roles are not in conflict with each other.
The current DPO for Cornerstone Partners is Monique Legair.
Furthermore, the following people have key areas of responsibility:
- The Board of Cornerstone Partners is ultimately responsible for ensuring that we meet our legal obligations.
- The Data Protection Officer, Monique Legair, is responsible for:
- keeping the executive committee 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 we hold about them (also called ‘subject access requests’); and
- checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
- The Head of Technology, Hafis Raji, is responsible for:
- ensuring 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; and
- evaluating any third-party services the company is considering using to store or process data (e.g. cloud computing services).
- The Head of Marketing, Andrew Ekpenyong, 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; and
- where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
General staff guidelines
- 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, members can request it from the appropriate member and there should be a paper or electronic trail
- Cornerstone Partners will provide training to all partners, interns and volunteers to help them understand their responsibilities when handling data.
- Partners, interns and volunteers should keep all data secure, by taking sensible precautions and following the guidelines below.
- In particular, strong passwords must be used and they should never be shared. We should consider using password managers as well
- 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.
Partners, interns and volunteers should request help from the data protection officer if they are unsure about any aspect of data protection
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Head of Technology or data controller.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see 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.
- Partners, interns and volunteers should 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. Burning or dissolving in water may be applicable as well.
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 partners, interns and volunteers.
- If data is stored on removable media (like a CD or DVD), 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 service (e.g. OneDrive).
- 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 our 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.
- Data breaches should be reported and recorded within 72 hours of discovery to the Head of Technology and the DPO. Staff will be notified and informed of mitigation measures regarding the breach
Data Use & Mitigation
- When working with personal data, partners, interns and vlunteers should ensure the screens of their personal computers and laptops are always locked when left unattended.
- Personal data should not be shared informally
- Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
- Personal data should never be transferred outside of the European Economic Area.
Partners, interns and volunteers should not save copies of personal data to their own computers. Always access and update the central copy of any data. The law requires Cornerstone Partners 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 we should put into ensuring its accuracy.
It is the responsibility of all partners, interns and volunteers who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible to ensure efficiency
- Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
- Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
- We will make it easy for data subjects to update the information we hold 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 Head of Marketing’s responsibility to ensure marketing databases are checked against industry suppression files every six months. (we can make it quarterly in line with standard business review timelines)
Data Subject access requests (DSAR)
All individuals who are the subject of personal data held by Cornerstone Partners 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.
DSARs from individuals should be made by email, addressed to the data controller at email@example.com. The data controller can supply a standard request form, although individuals do not have to use this.
GDPR, Article 12 (5) states that the response to a DSAR must be provided free of charge unless the request is deemed to be manifestly unfounded, excessive or repetitive in character, whereby the Data Controller can levy a reasonable fee taking into account the administrative burden associated to/with a response.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
DSARs must be fulfilled “without undue delay”, and at the latest within one month of receipt where requests are complex or numerous, organisations are permitted to extend the deadline to three months. However, they must still respond to the request within a month and explain why the extension is necessary.
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, we 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.
Cornerstone Partners 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.
This is available on request. A version of this statement is also available on the company’s website.
Please note that serious breaches of this data protection policy may result in serious disciplinary action but not before a verbal caution and a written caution.