Key Detail

–    Policy prepared by:             M S McGregor
–    Policy became operational on:     8 Jun 18
–    Next review date:            8 Jun 23


Capricorn Fitness Ltd needs to gather and use certain information about individuals which can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.  This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards and to comply with the law.

Why this policy exists

This data protection policy ensures Capricorn Fitness Ltd:

–    Complies with data protection law and follows good practice.
–    Protects the rights of staff, customers and partners.
–    Is open about how it stores and processes individuals’ data.
–    Protects itself from the risks of a data breach.

Data protection law

The General Data Protection Regulation (GDPR) 2018 describes how organisations – including Capricorn Fitness Ltd – must collect, handle and store personal information.  These rules must apply regardless of whether data is stored electronically, on paper or other materials.  To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully in accordance with the following principles:

–    Be processed fairly and lawfully.
–    Be obtained only for specific, lawful purposes.
–    Be adequate, relevant and not excessive.
–    Be accurate and kept up to date.
–    Not be held for any longer than necessary.
–    Processed in accordance with the rights of data subjects.
–    Be protected in appropriate ways.
–    Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.
– Be permanently deleted from our systems should the client request it (termed as data erasure).
– Be available for view in written form for the client should they request it.


Policy Scope

This policy applies to:

–    All branches of Capricorn Fitness Ltd.
–    All staff and volunteers of Capricorn Fitness Ltd.
–    All contractors, suppliers and other people working on behalf of Capricorn Fitness Ltd.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998.  This can include:

–    Names
–    Addresses
–    Email addresses
–    Telephone numbers
–    Plus any other information relating to individuals

Data Protection Risks

This policy helps to protect Capricorn Fitness Ltd from security risks, including:

–    Breaches of confidentiality.   For instance, information being given out inappropriately.
–    Failing to offer choice.  For instance, all individuals should be free to choose how the company uses data relating to them.
–    Reputational damage.   For instance, the company could suffer if hackers successfully gained access to sensitive data.


Everyone who works for Capricorn Fitness Ltd has some responsibility for ensuring data is collected, stored and handled appropriately.  All personal data must be handled and processed in line with this policy and data protection principles.

The Board of Directors is ultimately responsible for ensuring that Capricorn Fitness Ltd meets its legal obligations.


–    The only people able to access data covered by this policy should be those who need it for their work.
–    Data should not be shared informally.  When access to confidential information is required, employees can request it from their line managers.
–    Capricorn Fitness Ltd will provide training to all employees to help them understand their responsibilities when handling data.
–    Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
–    In particular, strong passwords must be used and they should never be shared.
–    Personal data should not be disclosed to unauthorised people, either within the company or externally.
–    Data should be regularly reviewed and updated if it is found to be out of date.  If no longer required, it should be deleted and disposed of.
–    Employees should request help from their management if they are unsure about any aspect of data protection.


The rules describe how and where data should be safely stored.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

–    When not required, the paper or files should be kept in a locked, fire-proofed drawer or filing cabinet.
–    Employees should make sure paper and printouts are not left where unauthorised people could see them.
–    Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

–    Data should be protected by strong passwords that are changed regularly and never shared between employees.
–    If data is stored on removable media, these should be kept locked away securely when not in use.
–    Data should only be stored on designated drivers and servers and should only be uploaded to an approved cloud computing service.
–    Servers containing personal data should be sited in a secure location, away from general office space.
–    Data should be backed up frequently and those backups should be tested regularly, in line with the company’s standard backup procedures.
–    Data should never be saved directly to laptops or other mobile devices.
–    All servers and computers containing data should be protected by approved security software and a firewall.


Personal data is of no value to Capricorn Fitness Ltd unless the business can make use of it.  However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

–    When working with personal data, employees should ensure the screens of their computers are always locked when unattended.
–    Personal data should not be shared informally.  In particular, it should never by sent by email.
–    Data must be encrypted before being transferred electronically.
–    Personal data should never ne transferred outside of the EEA.
–    Employees should not save copies of personal data to their own computers; always access and update the central copy.


The law requires Capricorn Fitness Ltd to take reasonable steps to ensure that data is kept accurate and up to date.

–    Data will be held in as few places as necessary.
–    Data should be updated as inaccuracies are discovered.


All individuals who are the subject of personal data held by Capricorn Fitness Ltd are entitled to:

–    Ask what information the company holds about them and why.
–    Ask how to gain access to it.
–    Be informed how to keep it up to date.
–    Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a Subject Access Request.  These requests should be made in writing or email to Capricorn Fitness Ltd (Contact details available on the company website).  Capricorn Fitness Ltd will aim to provide the relevant data within 14 days and a small fee will be payable.

Note: Capricorn Fitness Ltd must verify the identification of anyone making such a request before any information is made available.

Disclosing Data for other Reasons

In certain circumstances the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.  Under these circumstances, Capricorn Fitness Ltd will disclose requested data after gaining verification that the request is legitimate.

Providing Information

Capricorn Fitness Ltd aims to ensure that individuals are aware that their data is being processed and that they understand:

–    How the data is being used.
–    How to exercise their rights.