Data Deletion & Shredding Policy for In Professional Development
- The deletion (destruction) of personal data is an important activity in data protection, given the fifth data protection principle’s requirement that “personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes”. In Professional Development follow the ICO guidelines on data deletion.
- Definitions
- Deletion – Personal data will be deemed deleted based on the following criteria;
- Personal data is not recoverable in anyway either electronically or physically via shredding and disposal,
- Personal data has been deleted with no intention on the part of the data controller (In Professional Development) to use or access this again, but which may still exist in the electronic ether. For example, it could be waiting to be over-written with other data.
- Identified to be be deleted but is in fact still held on our live system because, for technical reasons, it is not possible to delete this information without also deleting other information held in the same batch but the appropriate safeguards are put in place to protect deleted data from use.
- Archiving – Personal data will be deemed archived based on the following criteria;
- Data is stored in a structured, retrievable manner and is subject to data protection regulations as ‘live’ information.
- Deleting personal data
- Where a request is made to In Professional Development to delete personal data, we commit to acting swiftly and in line with the definitions outlined in this policy and the guidelines provided by the ICO. Period of Grace. However, the applicant may receive communications for a transitional period whilst we process the request.
- A request to delete personal data can be submitted in writing
- By post: FAO Data Controller, In Professional Development, Suite 6a, Blackthorn House, Skull House Lane, Appley Bridge, WN6 9DB
- Electronically: info@inpd.co.uk with the subject line Personal Data Deletion Request
- On receiving a request to delete personal data we may request further information before processing the request to:
- Ascertain and confirm the identity of the individual submitting the request or the authority of a third party on the applicants behalf. We may not respond to a request until we have confirmed the identify of an applicant or authority of a third party. This is to avoid personal data about one individual being sent to another, accidentally or as a result of deception.
- Acquire all the necessary information needed to satisfy the request and find the personal data covered by the request. We may not action a request to delete data until we have received this information.
- Data Deletion Requests that involve data held or provided by a legitimate third party or source will be passed directly to the data provider. The applicant will also be provided information and contact details of the provider.
- Membership
- Members of the In Professional Development Membership scheme (In the Know) who request their data to be deleted will also have their subscription cancelled.
- Members that end their subscription to In Professional Development Membership scheme (In The Know) or unsubscribe from receiving communications from us will not automatically have their data deleted.
- For further information please contact:
In Professional Development limited
FAO Data Controller,
In Professional Development,
Suite 6A, Blackthorn House,
Appley Bridge, Greater Manchester,
WN6 9DB.
info@inpd.co.uk
ICO
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire SK9 5AF.
casework@ico.org.uk