PML (Programme Management) Ltd
Data Protection Policy

Context and overview

Key details
 Policy prepared by: Helena Camp
 Approved by board / management on: 07/08/2023
 Policy became operational on: 07/08/2023
 Next review date: Annually

PML (Programme Management) Limited; (also known as ‘PML Group Holdings Limited’, ‘PML
Group’); may need to gather and use certain elements of information about individuals.
These can include customers, suppliers, business contacts, employees 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 PML (Programme Management) Limited:
 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
 Protects itself from the risks of a data breach

Data protection law
The General Data Protection Regulations (EU) 2016/679 describes how organisations — including
PML (Programme Management) Limited — must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other
To comply with the law, personal information must be collected and used fairly, stored safely and
not disclosed unlawfully.

The General Data Protection Regulations (EU) 2016/679 is underpinned by eight important
principles. These say that personal data must:
1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. 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:
 The head office of PML (Programme Management) Limited
 All branches of PML (Programme Management) Limited
 All staff and volunteers of PML (Programme Management) Limited
 All contractors, suppliers and other people working on behalf of PML (Programme
Management) Limited
It applies to all data that the company holds relating to identifiable individuals, even if that
information technically falls outside of The General Data Protection Regulations (EU) 2016/679.
This can include:
 Names of individuals
 Postal addresses
 Email addresses
 Telephone numbers
 …plus any other information relating to individuals

Data protection risks
This policy helps to protect PML (Programme Management) Limited 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 PML (Programme Management) Limited has some responsibility
for ensuring data is collected, stored and handled appropriately.

Each 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:
 The board of directors is ultimately responsible for ensuring that PML (Programme
Management) Limited meets its legal obligations.

 The Data Protection Officer, [Helena Camp], is responsible for:
o Keeping the board updated about data protection responsibilities, risks and issues.
o Reviewing all data protection procedures and related policies, in line with an
agreed schedule.
o Arranging data protection training and advice for the people covered by this
o Handling data protection questions from staff and anyone else covered by this
o Dealing with requests from individuals to see the data PML (Programme
Management) Limited holds about them (also called ‘subject access requests’).
o Checking and approving any contracts or agreements with third parties that may
handle the company’s sensitive data.

 The IT Manager, [Kim Newman], is responsible for:
o Ensuring all systems, services and equipment used for storing data meet
acceptable security standards.
o Performing regular checks and scans to ensure security hardware and software is
functioning properly.
o Evaluating any third-party services the company is considering using to store or
process data. For instance, cloud computing services.

 The Marketing Manager, [Kim Newman], is responsible for:
o Approving any data protection statements attached to communications such as
emails and letters.
o Addressing any data protection queries from journalists or media outlets like
o 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, employees can request it from their line managers.
 PML (Programme Management) Limited will provide training to all employees to help
them understand their responsibilities when handling data.
 Employees 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.
 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.
 Employees should request help from their line manager or the data protection officer 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 IT manager 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.
 Employees 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.

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 Flash Drive), 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.

Data use
Personal data is of no value to PML (Programme Management) Limited 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, employees should 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. 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.
 Employees should not save copies of personal data to their own computers.
Always access and update the central copy of any data.

Data accuracy
The law requires PML (Programme Management) Limited 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 PML
(Programme Management) Limited should put into ensuring its accuracy.
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.
 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.
 PML (Programme Management) Limited will make it easy for data subjects to update the
information PML (Programme Management) Limited 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
 It is the marketing manager’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 PML (Programme Management)
Limited 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
Subject access requests from individuals should be made by email, addressed to the data
controller at []. The data controller can supply a standard request
form, although individuals do not have to use this.
The data controller 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 General Data Protection Regulations (EU) 2016/679 allows personal
data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, PML (Programme Management) Limited 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.

Providing information
PML (Programme Management) Limited 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 KDrive.] Signed:
Kim Newman (MD)
07 August 2023

(original signed document available on our company files)