OW Hospitality Ltd

Data Protection Policy


Content and Overview


Key Details

                Policy prepared by                           Matthew P Jones – managing
                Approved                                            May 25, 2018
                Next review                                       May 25, 2019


OW Hospitality Limited (referred to here as OWH) is committed to data protection and data privacy. Complying with the General Data Protection Regulation (GDPR) and Data protections Acts.

OW Hospitality Ltd (OWH) needs to gather and use certain information about individuals.

These 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 mee the Company’s data protection standards – and to comply with the law.


Why this Policy Exists

This data protection policy ensures OWH:

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

Data Protection Law

The Data Protection Act 1998 describes how organisations – including OWH – must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper, or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by 8 important principles.  These say that personal data must:

1                     Be process fairly and lawfully

2                     Be obtained only for specific, lawful purposes

3                     Be adequate, relevant and not excessive

4                     Be accurate and kept up to date

5                     Not be held for any longer than necessary

6                     Processed in accordance with the rights of the data subject

7                     Br protected in appropriate ways

8                     Not be transferred outside of the European Economic Area, unless that country or territory also ensures and adequate level of protects

As an addendum to point 8, OWH may provide data to a fellow Oriental Weavers Group Company, normally based in the USA or Egypt.  These companies are made aware of the strict controls that should be placed on any data provided.


People, Risks and Responsibilities


This policy applies to:

The head office ow OWH
All branches of OWH
All staff and volunteers of OWH
All contractors, suppliers and other people working on behalf of OWH

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:

Name of Individuals
Postal address
Email address
Telephone numbers
Social media contact details
Instant messaging contact details
… Plus any other information relating to individuals


Data Protection Risks


The policy helps to protect OWH from some very real data 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 OWH has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

                The Board of Directors is ultimately responsible for ensuring OWH meets is legal obligations

                The Data Protection Officer (Matthew Jones) is responsible for:

                                Keeping the Board updated about data protection responsibilities, risks and issues.

Reviewing all data protection procedures and related policies, in line with an agreed

Arranging data protection training and advice for the people covered by this policy.

Handling all data protection questions from staff and anyone else covered by this policy.

Dealing with requests from individuals to see the data OWH holds about them (also called ‘subject access requests’)

Checking and approving any contracts or agreements with third parties that may handle the Company’s sensitive data.

                The IT Manager (Matthew Jones) is responsible for:

Ensuring all systems, services and equipment used for storing data meet acceptable security standards

Performing regular checks and scans to ensure security hardware and software is functioning properly

Evaluating third party services the Company is considering using to store or process data.  for instance, cloud computing services.

                The Marketing Manager (Matthew Jones) is responsible for:

Approving any data protection statements attached to communications such as emails and letters

Addressing any data protection queries from journalists or media outlets.

Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.


General Staff Guidelines


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 manager .

OWH 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, wither 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 line manager or the data protection officer if they are unsure about any aspect of data protection.


Data Storage


These rules describe how and where data should be safely stored.  Questions about storing data safely can be directed to the IT manager or data Controller.


When data is stored on paper, it should be kept in a secure place where unauthorised pople 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 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 a removable media, they should be locked away when not in use.

                Data should only be stored on designated drives 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.  Those backups should be tested regularly.

                Data should never be saved directly to laptops or other mobile devices like tablets or smart phones, unless required by the software and if so must be password protected.

                All servers and computers containing data should be protected by approved security software and firewall.


Data Use


Personal data is of no value 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 left unattended.

                Personal data should not be shared informally.  In particular, it should never be sent by email, as this form of communication is not secure.

                Data must be encrypted before being transferred electronically.

                Personal data should never be transferred outside of the European Economic Area.

                Employees should not save copies of personal data to their own computers.  Always access and update the central copy of the data.


Data Accuracy


The law requires OWH to take reasonable steps to ensure data is kept accurate and up to date.


The more important it is that the personal data is accurate, the greater the effort OWH should put into ensuring its accuracy.


                Data will be held in as few places as necessary.  Staff should not create any unnecessary additional data sets.

                Staff should take every opportunity to ensure data is updated.  For instance, nu confirming a customer’s details when they call.

                OWH will make it easy for data subjects to update the information OWH hols about them.

                Data should be updated as inaccuracies are discovered.


Subject Access Rights

All individuals who are subject of personal data held by OWH 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.

Subject access requests from individuals should be made by email, addressed to the data controller at matthew.jones@owhospitality.co.uk .  The data controller can supply a standard request form, although individuals do not have to use it.  The data controller will aim to provide the relevant data within 14 days.


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, OWH will disclose requested data.  However, the data controller will ensure the request is legitimate, seeking assistance from the Board and the Company’s legal advisers where necessary.




Issued by


OW Hospitality Ltd

Elgar House

Green Street


DY10 1JF


Telephone          0207 604 5000