Data Sharing Policy

As a company we are committed to protecting any personal data that we are responsible for.  To ensure that we are able to do this we need to carefully consider our process for the sharing of personal data.

This Policy should be read in conjunction with the company Data Protection Policy and associated policies listed there-in.

1. What is Personal Data?
1.1.  Personal data is data which can identify a living individual.  As such, it may be written, visual, audible or biometric data.

2. What is Data Sharing?
2.1.  Data sharing is the disclosure of data from one organisation to another or the disclosure of data between different parts of the company.

3.  What types of Data Sharing are we likely to be involved In?​​

3.1.  In the routine operation of our business we are likely to share data for the following purposes;

3.1.1.  Provision of employee data to a third-party pensions provider;

3.1.2.  Provision of personal information to a Preferred Suppliers List (PSL);    

3.1.3.  Provision of employee or contractor information to a third-party insurance body;

3.1.4.  Provision of payroll data to HMRC;

3.1.5.  Obtaining technical or HR advice;

3.1.6.  Answering queries from an individual employee or contractor;

3.1.7.  The onward provision of an individual’s services to an agency or end hirer client;

3.1.8.  The recruitment, employment or engagement of an individual;

- This list is not exhaustive.

4.  What do we need to consider?

4.1.  On any occasion where we will share personal data we need to consider if there are grounds for us to process the data.  Such grounds are;

4.1.1.  The data subject has given consent to the processing;

4.1.2.  The processing is necessary for the performance of a contract;  #

4.1.3.  The processing is necessary for compliance with a legal obligation;

4.1.4.   The processing is necessary for;  The administration of justice;  For the exercise of any functions of either House of Parliament;  For the exercise of any functions conferred on a person by an enactment or rule of law;  For the exercise of any functions of the Crown, a Minister of the Crown or a government department; or  For the exercise of any other functions of a public nature exercised in the public interest by a person.  The processing is necessary for the purposes of legitimate interests pursued by the controller or the third party to whom the data is disclosed;

4.2.  You must stop and consider –

4.2.1.  Are there grounds to process the data?  What are the grounds and is any additional evidence required?

4.2.2.  Are there grounds for you to share the data?

4.2.3.  Is the party that you will share the data with entitled to receive it?

4.2.4.  Are you sure of the identity of the third party to whom you will supply the data?

4.3.  If you are unsure you must seek advice from the office manager.

4.4.  On any occasion when you will share personal data you should consider;

4.4.1.  Refusing the request to share data if there are no grounds for the third party to receive it;

4.4.2.  Obtaining the consent of the data subject where required via completion of a consent form prior to provision of the data;

4.4.3.  Restricting the data supplied to only that which is necessarily required;

4.4.4.  Is it possible to anonymize the data prior to transmission?  Where this is possible, by measures such as redaction, this should be done.

4.4.5.  What risks apply to the transmission and what steps can you take to reduce or eliminate such risks e.g. encryption, password protection? 

4.4.6.  What is the most secure method of transmission?

4.4.7.  Keep a record of the sharing of the data on the relevant file.


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