Data Protection Act Policy

How We Handle Personal Data

Last updated: 08 June 2015

Introduction
AnotherTicket is required to maintain certain personal data about individuals for the purposes of satisfying operational obligations. The organization recognises the importance of the correct and lawful treatment of personal data; it maintains confidence in the organization and provides for successful operations.

The types of personal data that AnotherTicket may require include sensitive information about: personal details including name and address details. This personal data, whether it is held on paper, on computer, server or other media, will be subject to the appropriate legal safeguards as specified in the Data Protection Act 1998.

What is Data Protection Act?
The Data Protection Act (DPA) is a law designed to protect personal data stored on computers or in an organised paper filing system. Organizations, who handle personal information about individuals, have a number of legal obligations to protect the information under the Data Protection Act 1998.

Definitions
See below the definitions of the Data Protection Act 1998.

  • Data Controller – The person who (either alone or with others) decides what personal information the AnotherTicket will hold and how it will be held or used.
  • Data Protection Act 1998 – The UK legislation provides a framework for responsible behaviour by those using personal information.
  • Data Protection Officer – The person responsible for ensuring that it follows its data protection policy and complies with the Data Protection Act 1998.
  • Data Subject/Service User – The individual whose personal information is being held or processed by AnotherTicket (for example: An employee, buyer, seller or an organization).
  • 'Explicit’ consent – For sensitive personal data explicit consent must be given by the data subject. This requires active communication with the data subject and must specify the data, and the purposes for which the data is held. This would include specifying what data is passed on to the organizations.
  • Notification – Notifying the Information Commissioner about the data processing activities of AnotherTicket as certain activities may be exempt from notification.
  • Information Commissioner – The UK Information Commissioner responsible for implementing and overseeing the Data Protection Act 1998.
  • Processing – means collecting, amending, handling, storing or disclosing personal information.
  • Personal Information – Information about living individuals that enables them to be identified – e.g. name and address. It does not apply to information about companies and agencies but applies to named persons or employees within AnotherTicket.
  • Sensitive data – means data about:
    • Racial or ethnic origin
    • Political opinions
    • Religious or similar beliefs
    • Trade union membership
    • Physical or mental health
    • Sexual life
    • Criminal record check
    • Criminal proceedings relating to a data subject’s offences
    • Credit reference check

Data Controller
AnotherTicket Information Compliance Manager is the Data Controller under the Act, who is responsible and determines what purposes personal information held will be used for. The board is therefore ultimately responsible for implementation. It is also responsible, unless exempt, for notifying the Information Commissioner of the data it holds or is likely to hold, and the general purposes that this data will be used for.

Any questions or concerns about the interpretation or operation of this policy should be taken up in the first instance with the Information Compliance Manager.

Disclosure
AnotherTicket may share data with voluntary or other agencies.

The Data Subject will be made aware in most circumstances how and with whom their information will be shared. There are circumstances where the law allows AnotherTicket to disclose data (including sensitive data) without the data subject’s consent. These are:

  • Carrying out a legal duty or as authorized by the Secretary of State;
  • Protecting vital interests of a Data Subject or other person;
  • The Data Subject has already made the information public;
  • Conducting any legal proceedings, obtaining legal advice or defending any legal rights;
  • Monitoring for equal opportunities purposes – i.e. race, disability or religion;
  • Providing a confidential service where the Data Subject’s consent cannot be obtained or where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill Data Subjects to provide consent signatures.

AnotherTicket fully endorses and adheres to the eight principles of the Data Protection Act. These principles specify the legal conditions that must be satisfied in relation to obtaining, handling, processing, transportation, and storage of personal data. Employees and any others who obtain, handle, process, transport and store personal data for AnotherTicket must adhere to these principles.

The 8 Principles
The principles require that personal data shall:

  1. Be processed fairly and lawfully and shall not be processed unless certain conditions are met;
  2. Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose;
  3. Be adequate, relevant and not excessive for those purposes;
  4. Be accurate and, where necessary, kept up to date;
  5. Not be kept for longer than is necessary for that purpose;
  6. Be processed in accordance with the data subject’s rights;
  7. Be kept secure from unauthorized or unlawful processing and protected against accidental loss, destruction or damage by using the appropriate technical and organizational measures;
  8. And 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.

Criteria and Controls of Principles
AnotherTicket will, through appropriate management, strict application of criteria and controls:

  • 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 its operational needs or to comply with any legal requirements;
  • Ensure the quality of information used;
  • 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 and
    • The right to correct, rectify, block or erase information which is regarded as wrong information.
  • Take appropriate technical and organizational security measures to safeguard personal information;
  • Ensure that personal information is not transferred abroad without suitable safeguards;
  • Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information;
  • Set out clear procedures for responding to requests for information.

Access to Personal Data
All individuals who are the subject of personal data held by the AnotherTicket are entitled to:

  • Ask what information the Society holds about them and why;
  • Ask how to gain access to it;
  • Be informed how to keep it up to date;
  • Be informed what the Society is doing to comply with its obligations under the 1998 Data Protection Act. 

Right to Access Information
Employees and other subjects of personal data held by the AnotherTicket have the right to access any personal data that is being kept about them on computer and also have access to paper-based data held in certain manual filing systems. This right is subject to certain exemptions which are set out in the Data Protection Act. Any person who wishes to exercise this right should make the request in writing to the Information Compliance Manager.

Another Ticket Limited
Information Compliance Manager
11 Richmond Road
Rugby
Warwickshire
CV21 3AB
United Kingdom (UK)

AnotherTicket reserves the right to charge the maximum fee payable for each subject access request. If personal details are inaccurate, they can be amended upon request or can be amended by logging on to their account.

AnotherTicket aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 40 days of receipt of the request, unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual making the request.

Employee Responsibility
All employees at AnotherTicket are responsible for:

  • Checking that any personal data that they provide to the Society is accurate and up to date;
  • Informing the company of any changes to information which they have provided, e.g. changes of address;
  • Checking any information that the company may send out from time to time, giving details of information that is being kept and processed.

Data Security
The need to ensure that data is kept securely means that precautions must be taken against physical loss or damage, and that both access and disclosure must be restricted. All employees are responsible for ensuring that:

  • Any personal data which they hold is kept securely;
  • Personal information is not disclosed either orally or in writing or otherwise to any unauthorized third party.

Data Storage
Information and records relating to buyers and sellers will be stored securely and will only be accessible to authorized staff. Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.

It is the responsibility of AnotherTicket to ensure all personal and company data is non-recoverable from any computer system or servers previously used within the organization which has been passed on/sold to a third party.

Data Access and Accuracy
All Data Subjects have the right to access the information AnotherTicket holds about them. AnotherTicket will also take reasonable steps ensure that this information is kept up to date by asking data subjects whether there have been any changes.

In addition, AnotherTicket will ensure that:

  • It has a Data Protection Officer with specific responsibility for ensuring compliance with Data Protection;
  • Everyone processing personal information understands that they are contractually responsible for following good data protection practice;
  • Everyone processing personal information is appropriately trained to do so;
  • Everyone processing personal information is appropriately supervised;
  • Anybody wanting to make enquiries about handling personal information knows what to do;
  • It deals promptly and courteously with any enquiries about handling personal information;
  • It describes clearly how it handles personal information;
  • It will regularly review and audit the ways it hold, manage and use personal information;
  • It regularly assesses and evaluates its methods and performance in relation to handling personal information;
  • All staff is aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them.

Questions
If you have questions or concerns about this Data Protection Policy or information handling processes, you can contact us at talktous@anotherticket.com or write to the data controller at:

Another Ticket Limited
Data Controller
11 Richmond Road
Rugby
Warwickshire
CV21 3AB
United Kingdom (UK)

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