Data Protection Policy
1 It is the policy of Triumph Motorcycles Ltd ("the Company") to take all necessary steps to ensure that personal data held by the Company about its employees, customers, suppliers and all other individuals is processed fairly and lawfully. The Company will take all necessary steps to implement this policy.
2 It is the policy of the Company to ensure that all relevant statutory requirements are complied with and that the Company's internal procedures are monitored periodically to ensure compliance.
3 The Company will implement and comply with the eight Data Protection Principles contained in the Data Protection Act 1998 ("the Act") which promote good conduct in relation to processing personal information. These Principles are:
(i) Personal data shall be processed fairly and lawfully.
(ii) Personal data shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
(iii) Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which it is processed.
(iv) Personal data shall be accurate and, where necessary, kept up to date.
(v) Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
(vi) Personal data shall be processed in accordance with the rights of data subjects (i.e. individuals) under the Act.
(vii) Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
(viii) Personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
4 The attention of all employees is drawn to the data protection rules and procedures laid down by the Company from time to time. Employees have a duty to follow these rules and procedures and to co-operate with the Company to ensure this policy is effective. Disciplinary action may be taken against any employee who fails to comply with these rules and procedures. Employees should also be aware that if they knowingly or recklessly obtain or disclose personal data without the Company's consent, they may be committing a criminal offence.
5 The Company has a responsibility to ensure that personal data dealt with in the course of the Company's business is handled in accordance with statutory requirements and reasonable steps will be taken by all concerned to ensure this duty is observed.
6 The Company will consult with its employees periodically to ascertain what measures should be taken to increase awareness of data protection issues and to ensure that all necessary measures are taken to make this policy effective.
7 The Company will take such measures as may be necessary to ensure the proper training, supervision and instruction of all relevant employees in matters pertaining to data protection and to provide any necessary information.
8 As well as putting in place required contracts with third party processors of the Company's data, the Company will monitor on an ongoing basis the compliance of those processors with the provisions of the Act.
9 The person having overall responsibility for data protection will be the Data Protection Compliance Officer, details of whom can be obtained from the Company Secretary.
10 Each manager and supervisor will have immediate responsibility for data protection matters in his/her own area of work.
11 The Chief Information Officer will be responsible to continually review data security arrangements, monitor the risk of exposure to major threats to data security, review and monitor security incidents, and establish and implement initiatives to enhance data security.
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