Data Protection Policy
Stovesonline and Firepower
Data Protection Officer:
Sune Nightingale, you can contact me via firstname.lastname@example.org
1. Data protection principles
We are committed to processing data in accordance with its responsibilities under
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in
a manner that is incompatible with those purposes; further processing for archiving
purposes in the public interest, scientific or historical research purposes or
statistical purposes shall not be considered to be incompatible with the initial
c. adequate, relevant and limited to what is necessary in relation to the purposes for
which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be
taken to ensure that personal data that are inaccurate, having regard to the
purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal
data may be stored for longer periods insofar as the personal data will be processed
solely for archiving purposes in the public interest, scientific or historical research
purposes or statistical purposes subject to implementation of the appropriate
technical and organisational measures required by the GDPR in order to safeguard
the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data,
including protection against unauthorised or unlawful processing and against
accidental loss, destruction or damage, using appropriate technical or
2. General provisions
a. This policy applies to all personal data processed by us.
b. The Data Protection Officer takes responsibility for our ongoing
compliance with this policy.
c. This policy shall is reviewed at least annually.
d. We are registered with the Information Commissioner’s Office as a
Data controller. Reference: Z267172X
3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, we
maintain a Data Mapping document which tracks the systems we use to hold data and access.
b. This document is reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made
shall be dealt with in a timely manner. Please simply contact the Data Protection Officer.
4. Lawful purposes
a. All data processed by is must be done on one of the following lawful bases:
consent, contract, legal obligation, vital interests, public task or legitimate interests
b. We note the appropriate lawful basis in the our Data Mapping document.
c. Where communications are sent to individuals based on their consent, the option
for the individual to revoke their consent should be clearly available.
5. Data minimisation
a. We work to ensure that we only gather the personal information needed. For example we do not mandate address info on our enquiry forms.
a. We take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put
in place to ensure that personal data is kept up to date.
7. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, we have
put in place an archiving policy for each area in which personal data is processed. We review this annually. This is detailed in our Data Mapping document.
b. The archiving policy shows what data should/must be retained, for how long,
a. We ensure that personal data is stored securely using modern
software that is kept-up-to-date.
b. Access to personal data is limited to personnel who need access and
appropriate security is in place to avoid unauthorised sharing of
c. When personal data is deleted this should be done safely such that the data is
d. Appropriate back-up and disaster recovery solutions are in place.
e. Data communicated via our websites are fully secured with SSL, and personal information stored in the new systems we are moving to are fully encrypted.
In the event of a breach of security leading to the accidental or unlawful destruction, loss,
alteration, unauthorised disclosure of, or access to, personal data, we shall
promptly assess the risk to people’s rights and freedoms and if appropriate report this
breach to the ICO.