1. Digital Academy of Dental Sciences (DADS) (the Employer, we or our) is committed to the highest standards of information security and treats data security and confidentiality extremely seriously.
2. This policy and the rules contained in it apply to all staff of the Employer, irrespective of seniority, tenure and working hours, including all employees, directors and officers, consultants and contractors, temporary and agency workers, trainees, casual and fixed-term staff, apprentices, interns and any volunteers (Staff or you).
3. All Staff must familiarise themselves with this policy and comply with its terms.
a. ensure the security of personal data, including protection against any unlawful or unauthorised data processing and accidental loss, damage or destruction, by utilising appropriate technical or organisational measures;
b. demonstrate the consideration and integration of data compliance measures into the Employer’s data processing activities, by implementing appropriate technical or organisational measures; and
c. be able to demonstrate the use and implementation of such appropriate technical or organisational measures.
a. protect against any potential breaches of confidentiality;
b. protect the Employer’s informational assets and IT systems and facilities against any loss, damage or misuse;
c. supplement the Employer’s Data Protection and Security Policy in ensuring that Staff are aware of and comply with UK laws and the Employer’s policies and procedures on the processing of personal data; and
d. raise awareness of and clarify the responsibilities and duties of Staff in respect of information security, data security and confidentiality.
6. This is a statement of policy only and does not form part of your contract of employment. The Employer may amend this policy at any time, in our absolute discretion, and we will do so in accordance with our data protection and other obligations. A new copy of the policy will be circulated whenever it is changed.
a. Business Information means any of the Employer’s business-related information other than personal data about customers, clients, suppliers and other business contacts;
b. Confidential Information means any trade secrets or other confidential information (belonging to the Employer or third parties) processed by the Employer;
c. Personal Data means any information that relates to an individual who can be identified from that information, either directly or indirectly; and
d. Sensitive Personal Data means information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (or non-membership), health, sex life, sexual orientation, genetic information or biometric information (where this is used to identify an individual).
a. implement and maintain this policy;
b. monitor potential and actual security breaches;
c. ensure Staff are aware of their responsibilities in relation to information security and confidentiality; and
d. ensure compliance with the UK GDPR and all other relevant legislation and guidance.
a. paper records;
b. hand-held devices;
d. information stored on computer systems; and
e. information passed on verbally.
a. Personal Data relating to Staff, customers, clients or suppliers;
b. other Business Information; and
c. Confidential Information.
a. Employee Privacy Notice.
b. Data Retention Policy.
c. Communications and Use of Equipment Policy.
d. The content of these policies must be considered and taken into account alongside this policy.
a. treated as commercially valuable; and
b. protected from loss, theft, misuse or inappropriate access or disclosure.
a. unauthorised and/or unlawful processing; and
b. accidental loss, destruction or damage.
14. Staff and line managers should discuss what security measures (including technical and organisational measures) are appropriate and which exist to protect any information accessed by Staff in the course of employment.
15. Any information, apart from Personal Data, is owned by the Employer and not by an individual or team.
16. Any information must only be used in connection with work being undertaken for the Employer. It must not be used for any other personal or commercial purposes.
17. Any Personal Data must only be processed for the specified, explicit and legitimate purpose for which it is collected.
a. the data protection principles;
b. the Employer’s policies on data protection generally (including the Data Protection and Security Policy); and
c. the Employer’s other relevant policies.
a. adequate, relevant and limited to what is necessary for the relevant purposes; and
b. kept accurate and up to date.
a. The encryption of Personal Data.
b. The pseudonymisation of Personal Data.
c. Dual-factor authentication.
d. The use of strong passwords.
e. Password protection on any documents containing Sensitive Personal Data.
f. Strictly limited access rights to certain datasets to ensure only those authorised to process Personal Data have access.
21. Any Personal Data and Confidential Information must not be kept any longer than is necessary and will be stored and destroyed in accordance with our Data Retention Policy.
22. Due to the internal confidentiality of personnel files, access to these files and any information contained therein is limited to the HR Department. Non-HR Staff are not authorised to access HR information, except as provided for in any individual roles.
a. the recruitment process;
b. a management role; or
c. a supervisory role.
24. Under the UK GDPR and other relevant legislation, Staff may ask to see their personnel files and obtain access to any other Personal Data about them. For more information on this process, see the Employer’s policy on making subject access requests, which is available from the HR Department and online at: .
25. All office doors, office keys and access codes must, at all times, be kept secure. Office keys and access codes must at no time be given to or communicated to any third parties.
26. All documents containing and any equipment displaying Confidential Information should be placed and positioned so that anyone passing by cannot see them (e.g. through office windows or glass doors).
a. sign it at reception;
b. be accompanied by Staff at all times; and
c. not be left alone in areas or situations where they may have access to Confidential Information.
28. Meetings with visitors must, where possible, take place in meeting rooms. If a visitor meeting takes place outside a meeting room, in an office or other room containing Employer information, steps must be taken to ensure no Confidential Information is visible and accessible to the visitors.
a. whenever desks are unoccupied; and
b. at the end of the working day.
30. Where available on our systems, password protection and encryption must be used to maintain confidentiality.
31. All computers and other electronic devices must be password protected. Such passwords must be changed regularly and must not be recorded anywhere (e.g. written down) or made available to others.
32. To minimise the risk of accidental loss or disclosure, all computers and other electronic devices must be locked when not in use, including when left unattended at a desk.
33. All data held electronically must be securely backed up as soon as possible in accordance with the Employer’s internal backup procedure.
34. Confidential Information must not be copied onto removable hard drives, CDs or DVDs, floppy disks or memory sticks, without the express permission of the IT Department. Any Personal Data held on such devices must, as soon as possible, be transferred to the Employer’s computer network to be backed up and then deleted from the device.
a. ensure that they do not introduce viruses, malware or malicious codes onto the Employer’s systems.
b. not install or download from the internet any software without it first being checked for viruses. Staff should speak to the IT Department for more information and guidance on appropriate steps to be taken to ensure compliance.
36. When speaking in public places (e.g. when speaking on a mobile phone), Staff must take care in maintaining confidentiality.
37. Confidential Information must be marked ‘strictly private and confidential’ and circulated only to those who need to know the information in the course of their work.
38. Confidential Information must not be removed from the Employer’s offices (and systems) unless required for authorised business purposes, and then only in accordance with the subsequent paragraph.
a. stored with strong password protection, which is kept locked when not in use;
b. not transported in see-through or other unsecured bags or cases, when in paper copy;
c. not read in public places when working remotely (e.g. in waiting rooms or on trains); and
d. not left unattended or in any place where it is at risk (e.g. in airports or conference centres).
40. Care must be taken to verify all postal and email addresses before any information is sent to them. Particular care must be taken when checking and verifying email addresses where auto-complete features may have inserted incorrect email addresses.
41. Before being sent by email or recorded delivery, all sensitive or particularly confidential information should be encrypted.
42. Personal email accounts (e.g. Google, Hotmail and Yahoo) and cloud storage services (e.g. Google Drive, iCloud and OneDrive) are vulnerable to hacking and do not provide the same level of security as the services provided by the Employer’s IT systems.
43. Staff must not use personal email accounts or cloud storage accounts for work purposes.
44. If large amounts of data need to be transferred, Staff should speak to the IT Department.
45. Unless required for authorised business purposes, and then only in accordance with the subsequent paragraph, Staff must not take information home with them.
a. kept in a secure and locked location, where it cannot be accessed by others (including family members and guests); and
b. retained and disposed of in accordance with paragraph 21 above.
47. Staff must not store any Confidential Information on their home computers or other devices (e.g. laptops, PCs or tablets).
48. For more information, see the Employer’s Working From Home Policy available from the HR Department and online at: .
49. Third party service providers should only be engaged to process information where appropriate written agreements are in place to ensure that they offer appropriate data protection, confidentiality and information security protections and undertakings. Care must be taken to consider whether any such third party service providers will be considered data processors for the purpose of the UK GDPR.
50. Staff involved in the process of setting up new arrangements or altering existing arrangements with third parties should speak to and consult with the DPO for more information and guidance.
51. There are restrictions on (onward) transfers of Personal Data to international organisations outside of the UK. Staff may only transfer Personal Data outside the UK (including to international organisations outside the UK) if there are sufficient and adequate protections in place. Before making any transfers, Staff should speak to, and seek written authorisation from, the DPO.
52. For more information, see the Employer’s Data Protection and Security Policy available from the DPO and online at: . If you have any questions or concerns please contact the DPO or Legal Department.
53. The Employer will provide training on the concepts and measures contained in this policy to all Staff as part of the induction process and at regular intervals thereafter or whenever there is a substantial change in the law or our policies and procedures.
54. Training is provided online and Instructor Lead Training. The completion of such training is compulsory. The Employer will continually monitor training needs but if you feel that you need further training on any aspect of the relevant law or this policy, please contact the DPO.
56. For more information on the Employer’s reporting procedure, contact the DPO.
57. The Employer takes compliance with this policy very seriously and failure to comply with this policy puts Staff and the Employer alike at significant risk.
58. Due to the importance of this policy, failure to comply with any of its procedures and requirements may result in disciplinary action and dismissal.
59. If you have any questions or concerns about anything in this policy, please contact the DPO at firstname.lastname@example.org.
60. This Information Security Policy was created using a document from Rocket Lawyer (https://www.rocketlawyer.com/gb/en).