DATA PROTECTION

We regard the lawful and correct treatment of personal information by the College as very important to successful operations and for maintaining confidence between ourselves and those with whom we deal.

We therefore make every effort to ensure that personal information is treated lawfully and correctly.

Henley Management College needs to collect a range of personal information in order to operate. This includes current, past and prospective employees, suppliers, clients/customers, and others with whom it communicates. The College requires this information to support the administration of contracts with these people and, in addition, it may occasionally be required by law to collect and use information of this kind to comply with the requirements of government departments for business data, for example. 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 the Data Protection Act 1998.

We fully endorse and adhere to the Principles of data protection, as detailed in the Data Protection Act 1998.

Specifically, the Principles require that personal information:

shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met;
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;
shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed;
shall be accurate and, where necessary, kept up to date;
shall not be kept for longer than is necessary for that purpose or those purposes;
shall be processed in accordance with the rights of data subjects under the Act;
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. The European Economic Area comprises of the following countries: Austria, Belgium, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Holland, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Norway, Poland, Portugal, Slovak, Slovenia, Spain, Sweden, United Kingdom.
and that:
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;

Therefore, Henley Management College will, through appropriate management, and 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 operational needs or to comply with any legal requirements;
ensure the quality of information used;
apply strict checks to determine the length of time the information is held;
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; the right to correct, rectify, block or erase information which is regarded as the wrong information.);
take appropriate technical and organisational security measures to safeguard personal information;
ensure that personal information is not transferred abroad without suitable safeguards.

In addition, Henley Management College will ensure that:

there is someone with specific responsibility for data protection in the organisation (the Data Protection Officer);
everyone managing and handling personal information understands that they are contractually responsible for following good data protection practice;
everyone managing and handling personal information is appropriately trained to do so;
any third party organisation that processes data on our behalf has adequate measures in place and provides us with written guarantees to this effect;
queries about handling personal information are promptly and courteously dealt with;
methods of handling personal information are clearly described;
regular review and assessment is made of the way personal information is managed;

Anybody wanting to make enquiries about handling personal information should contact the Data Protection Officer or the Personnel Office in the first instance.

The College expects all employees with access to personal information to respect the need for confidentiality and to avoid improper use or transfer of such information. Any employee who fails to adhere to these principles may be subject to disciplinary action.

November 2004

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