Data Protection Policy

Firntec needs to collect and use certain types of information about customers and other individuals who come into contact with Firntec.  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 Data Protection Legislation. 

Firntecs data protection and privacy practices are governed by the following legislation: 

• UK General Data Protection Regulation (UK GDPR) – The retained EU law version of the GDPR that applies in the UK following. 

• Data Protection Act 2018 – The UK’s implementation of the GDPR, providing additional provisions and exemptions. 

• Privacy and Electronic Communications Regulations (PECR) – Governs electronic communications, including the use of cookies, email and SMS marketing, and more. 

• Information Commissioner’s Office (ICO) Guidance – Regulatory guidance from the UK’s independent authority for data protection. 

Firntec reviews all data handling and privacy procedures in line with these regulations to ensure full compliance and uphold the rights of individuals. 

Firntec is an ICO-registered data controller and processor (registration no. ZA484399).  

Specifically, the Principles require that personal information: 

1. Shall be processed fairly and lawfully and shall not be processed unless 
   specific conditions are met. 
2. 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. 
3. Shall be adequate, relevant and not excessive in relation to the purpose or purposes for 
   which they are processed. 
4. Shall be accurate and, where necessary, kept up to date. 
5. Shall not be kept for longer than is necessary for that purpose or those purposes. 
6. Shall be processed in accordance with the rights of data subjects. 
7. 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. 
8. 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. 

Firntec will, through appropriate management and strict application of criteria and controls: 

1. Observe fully conditions regarding the fair collection and use of information. 
2. Meet its legal obligations to specify the purposes for which information is used. 
3. 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. 
4. Ensure the quality of information used. 
5. Apply strict checks to determine the length of time information is held. 
6. 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). 
7. Take appropriate technical and organisational security measures to safeguard personal 
   information. 
8. Ensure that personal information is not transferred abroad without suitable safeguards. 
9. Treat people justly and fairly whatever their age, religion, disability, gender, sexual 
   orientation or ethnicity when dealing with requests for information. 
10. Set out clear procedures for responding to requests for information. 

In addition, Firntec will ensure that: 

1. There is someone with specific responsibility for Data Protection. Firntecs Data Protection 
   Officer is Frazer Keam. 
2. Everyone managing and handling personal information understands that they are contractually responsible for following good data protection practice. 
3. Everyone managing and handling personal information is appropriately trained to do so. 
4. Everyone managing and handling personal information is appropriately supervised. 
5. Anybody wanting to make enquiries about handling personal information knows what to do. 
6. Queries about handling personal information are promptly and courteously dealt with. 
7. Methods of handling personal information are clearly described. 
8. A regular review and audit is made of the way personal information is held, managed and 
   used. 
9. Methods of handling personal information are regularly assessed and evaluated. 
10. Performance with handling personal information is regularly assessed and evaluated. 
11. A breach of the rules and procedures identified in this policy by a member of staff may 
    lead to disciplinary action being taken. 

The Controller for the purposes of the General Data Protection Regulation (GDPR), other data 
protection laws applicable in Member states of the European Union and other provisions related to 
data protection is: Frazer Keam 

This policy will be updated as necessary to reflect best practice in data management, security and 
control and to ensure compliance with any changes or amendments made to the Data Protection Act 2018 and/or GDPR.