Llewellin’s Machine Company Limited 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 will be obtained, handled, processed, transported and stored lawfully and correctly, in accordance with the safeguards contained in the General Data Protection Regulation (GDPR).

Why this Policy exists

This Data Protection Policy ensures that Llewellin’s Machine Company Limited:

  • Complies with Data Protection Law in accordance with GDPR and follows good practice

  • Protects the rights of staff, customers, suppliers and associates

  • 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) describes how organisations – including Llewellin’s Machine Company Limited 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 General Data Protection Regulation is underpinned by eight important principles. These say that personal data must:

  • Be fairly and lawfully processed

  • 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 data subject’s rights under GDPR

  • Be protected and kept secure from unauthorised or unlawful processing and protected against accidental loss, destruction or damage

  • Not be transferred outside the European Economic Area (EEA), unless the country or territory also ensures adequate level of protection


People, risks and responsibilities – Policy Scope

This Policy applies to:

  • Llewellin’s Machine Company Limited

  • All staff of Llewellin’s Machine Company Limited

  • All Contractors, Suppliers and other people working on behalf of Llewellin’s Machine Company Limited.

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

  • Names of individuals

  • Postal addresses

  • Email addresses

  • Telephone numbers

  • …plus any other information relating to individuals

Data Protection Risks

This Policy helps to protect Llewellin’s Machine Company Limited 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 or with Llewellin’s Machine Company Limited has some responsibility for ensuring data is collected, stored and handled appropriately.

Each individual that handles personal data must ensure that it is handled and processed in line with this Policy and GDPR principles.

The Directors are ultimately responsible for ensuring that Llewellin’s Machine Company Limited meets its legal obligations. They are responsible for:

  • Keeping updated about Data Protection responsibilities, risks and issues.

  • Reviewing all Data Protection procedures and related policies, in line with an agreed schedule.

  • Handling Data Protection questions from staff and anyone else covered by this Policy.

  • Dealing with requests from individuals to see the data Llewellin’s Machine Company Limited holds about them (also called ‘subject to access requests’)

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

  • 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 any third-party services, the Company is considering using to store or process data. For instance, cloud computing services.

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

  • 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.

  • 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 the Directors 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 Directors.

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

  • 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, like on a printer.

  • 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, being disclosed only to the Directors.

  • If data is stored on removable media (like CD or DVD), these should be kept locked away securely when not being used.

  • Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service, as directed by our IT Contractors Severnside Software Ltd.

  • 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, in line with the Company’s standard backup procedures.

  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.

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

Data Use

Personal data is of no value to Llewellin’s Machine Company Limited 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. If in doubt, please contact Severnside Software Ltd.

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

Data Accuracy

The law requires Llewellin’s Machine Company Limited 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 Llewellin’s Machine Company Limited should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in a few places as necessary. Staff should not create any un-necessary additional data sets.

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

  • Llewellin’s Machine Company Limited will make it easy for data subjects to update the information Llewellin’s Machine Company Limited holds about them. For instance, via the Company website.

  • Data should be updated as inaccuracies are discovered. For instance, if a Customer can no longer be reached on their stored telephone number, it should be removed from the database.

Subject Access Requests

All individuals who are the subject of personal data held by Llewellin’s Machine Company Limited are entitled to:

  • Ask what information the Company holds about them and why.

  • Ask how to gain access to this information.

  • Be informed how to keep it up to date.

  • Be informed how the Company is meeting its GDPR obligations.

If individuals contact the Company requesting this information, this is called ‘subject access request’.

Subject access request from individuals should be made by either letter or email for the attention of the Directors.

The Directors will aim to provide the relevant data as soon as possible but do have up to one month to comply.

The Directors can refuse requests which are unfounded or excessive.

Disclosing Data for other reasons

In certain circumstances, the GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Llewellin’s Machine Company Limited will disclose requested data. However, the Directors will ensure the request is legitimate, seeking assistance from the Company’s legal advisers where necessary.



Name: Ms J A Quant …………………………………
Position: Managing Director
Date: 4th June 2018