Data Protection and Subject Access Policy

9. Responsibilities of Individual Data Users

9.1 All employees and Members of the council who record and/or process personal data in any form (called "Data Users" in this policy) must ensure that they comply with:

a) The requirements of the UK General Data Protection Regulation 2016  (including the Data Protection Principles);
b) The council's Data Protection Policy, including any procedures and guidelines which may be issued from time to time.

9.2 A breach of the General Data Protection Regulation 2016 and/or the council's Data Protection Policy may result in disciplinary action.

9.3 Consideration should be given towards contacting the Information Governance Team for data protection advice concerning the following:

a) When developing any new system for processing personal data - it may also be necessary to comply with the council's Information Asset Change Policy and Data Privacy Impact Assessment Policy;
b) When using an existing computer system to process personal data for a new purpose as it may be necessary to notify an amendment to an existing registration in the council's Information Asset Change Policy, and it will be necessary to document the new processing activity;
c) When creating a new manual filing system containing personal data;
d) When using an existing manual filing system containing personal data for a new purpose.

10. Contractors and Data Processors

10.1 Outside agents working with Wiltshire Council data will be required to ensure full data compliance in accordance with contractual arrangements. Wiltshire Council reserves the right to inspect contractors and data processors to satisfy these requirements.

11. Accuracy of Data

11.1 Staff that have responsibility for handling any client, staff or other individual's personal information must ensure that it is accurate and as up to date as possible.

11.2 All staff members are responsible for checking that any personal information they provide to the council in connection with their own employment is accurate and up to date e.g. change of address or name.

11.3 The council cannot be held responsible for issues arising from any errors in such employment data unless the member of staff has informed the council about any relevant changes of circumstance.