Luminous Living Ltd needs to gather and use certain
information about individuals.
These can include (current and
former) 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 meet our data protection
standards, privacy notice – and to comply with the law.
Why this policy exists
This data protection policy
ensures Luminous Living Ltd :
• Complies with data protection
law and follows good practice.
• Protects the rights of
employees, customers, affiliates and partners.
• Is open about how it stores and
processes individuals’ data.
• Protects itself from the risks
of a data breach.
Data Protection Law
The Data Protection Act 1998 and
the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679)
describe how organisations – including Luminous Living Ltd – 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 1998 and
General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) are
underpinned by eight important principles. These say that personal data must:
1. Be processed 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 data subjects
7. Be protected in appropriate
ways
8. Not be transferred outside the
European Economic Area (EEA), unless that country or
territory also ensures an
adequate level of protection
People, Risks and Responsibilities
Policy Scope
This policy applies to:
• The head office of Luminous
Living Ltd
• All branches of Luminous Living
Ltd
• All employees and Directors of Luminous
Living Ltd
• All contractors, suppliers and
other people working on behalf of Luminous Living Ltd
It applies to all data that the
firm holds relating to the identifiable individuals, even if that
information technically falls
outside of the Data Protection Act 1998 and the General Data
Protection Regulation (GDPR)
(Regulation (EU) 2016/679). This can include:
• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Any other information relating
to individuals
Data Protection Risks
This policy helps to protect Luminous
Living Ltd 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
firm uses data relating to them.
• Reputational damage. For
instance, the company could suffer if hackers successfully
gained access to sensitive data.
Responsibilities
Everyone who works for or with Luminous
Living Ltd 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 Directors are ultimately
responsible for ensuring that Luminous Living Ltd meets
its legal obligations.
The Data Protection Officer is responsible for:
• Keeping the Directors updated
about data protection responsibilities, risks and issues.
• Reviewing all data protection
procedures and related policies, in line with an agreed
procedure.
• Arranging data protection
training and advice for the people covered by this policy.
• Handling data protection
questions from employees and anyone else covered by this
policy.
• Dealing with requests from
individuals to see the data Luminous Living Ltd 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.
• 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 data protection
statements attached to communications such as emails and
letters.
• Addressing any data protection
queries from journalists or media outlets like
• Where necessary, working with
other employees 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 managers.
• Luminous Living Ltd 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, either within the firm 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 / Data Controller.
When data is stored on paper, it
should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to
data that is usually stored electronically but has been printed
out for some reason and to original copies of documents:
• When not required, the paper or
file 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.
• Paper Documents, especially
originals of official purpose such as certificates or similar
must be sent using tracked delivery services which obtain a signature upon delivery.
• Documents sent outside the UK
should always be sent by a reputable international
courier using tracked delivery
services which obtain a signature upon delivery.
• When data is stored
electronically, it must be protected from unauthorised access,
accidental deletion and malicious
hacking attempts.
• All computers should have
encrypted local disk drives.
• Data should be protected by
strong passwords that are changed regularly and never
shared between employees.
• Data stored on USB drives, CD’s
or DVD’s is not permitted. Any data sent to us in these
formats should be given to IT for
transfer to the correct secure storage location and the
media should then be properly
destroyed.
• 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, in line
with the firm’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 a firewall.
Data Use
Personal data is of no value to Luminous
Living Ltd 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. The IT Manager can
explain how to send data to
authorised external contacts.
• 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 any data.
Data Accuracy
The law requires Luminous Living
Ltd 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 Luminous Living Ltd 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 as few
places as necessary. Staff should not create any unnecessary
data sets.
• Staff should take every
opportunity to ensure data is updated. For instance, by
confirming a customer’s details
when they call.
• Luminous Living Ltd will make
it easy for data subjects to update the information
they about them; for example, via
regular contact and review
of data.
• 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.
• It is the marketing manager’s
responsibility to ensure marketing databases are checked
against industry suppression
files every six months.
Subject Access Requests
All individuals who are the
subject of personal data held by Luminous Living Ltd are entitled to:
• Ask what information the firm
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
firm 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 (Charmaine
Davis) to info@luminousliving.co.uk. The data controller
can supply a standard request form, although individuals do not have to use
this.
The data controller will always
verify the identity of anyone making a subject access request
before handing over any
information.
Disclosing Data for other Reasons
In certain circumstances, the
Data Protection Act and the General Data Protection Regulation allows personal
data to be disclosed to law enforcement agencies without the consent of the
data subject.
Under these circumstances, Luminous
Living Ltd will disclose requested data. However, the data controller will
ensure the request is legitimate, seeking assistance from the Directors and
from the firm’s legal advisers where necessary.
Providing Information
Luminous Living Ltd aims to
ensure that individuals are aware that their data is being
processed, and that they
understand:
• How the data is being used.
• How to exercise their rights.
To these ends, the firm has a
general privacy statement setting out how data relating to
individuals is used by the firm.
Privacy Notice
Luminous Living Ltd conduct work
for clients in a range of areas and must collect data for this purpose. This
privacy notice explains how we use any personal information we collect about
you.
What information do we collect about you?
We collect information about you
when you engage us for advice or services. This information will relate to your
personal and financial circumstances. It may also include special categories of
personal data such as data about your health, if this is necessary for the
provision of our services.
We may also collect information
when you voluntarily complete client surveys or provide
feedback to us.
Why do we need to collect and use your personal data?
The primary legal basis that we
intend to use for the processing of your data is for the
performance of our contract with
you. The information that we collect about you is essential
for us to be able to carry out
the services that you require from us effectively. Without
collecting your personal data
we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is
required we’ll obtain your explicit consent in order to collect
and process this information.
How will we use the information about you?
We collect information about you
in order to provide you with the services for which you
engage us.
Who might we share your information with?
If you agree, we may email you about other
products or services that we think may be of
interest to you.
If you agree, we’ll pass on your contact
information to our group of companies so that they
may offer you their products and
services.
We won’t share your information
for marketing purposes with any third party.
In order to deliver our services
to you effectively we may send your details to third parties such as those that
we engage for professional compliance, accountancy or legal services or other
credentialed specialist advisers.
Where third parties are involved
in processing your data we’ll have a contract in place with
them to ensure that the nature
and purpose of the processing is clear, that they are subject to a duty of
confidence in processing your data and that they’ll only act in accordance with
our written instructions.
Where it’s necessary for your
personal data to be forwarded to a third party we’ll use
appropriate security measures to
protect your personal data in transit.
To fulfil our obligations in
respect of prevention of money-laundering and other financial crime we may send
your details to third party agencies for identity verification purposes and
this search will be recorded as an identity check. It will not affect your
ability to obtain credit.
How long do we keep hold of your information?
In principle, your personal data
shouldn’t be held for longer than is required under the terms
of our contract for services with
you. However, we’re subject to regulatory requirements to
retain data for specified minimum
periods, usually between 7 and 10 years. We also reserve
the right to retain data for
longer than this in order to be able to provide you with long term
analyses, trends and reports or
other business data and to allow us to assist you should you be subject to an
HMRC enquiry or investigation.
You have the right to request
deletion of your personal data. We’ll comply with this request,
subject to the restrictions of
our regulatory obligations and legitimate interests as noted
above.
How can I access the information you hold about me?
You have the right to request a
copy of the information that we hold about you. If you’d like a
copy of some or all of your
personal information, please email or write to us using the contact details
noted below.
When your personal data is
processed by automated means you have the right to ask us to
move your personal data to
another organisation for their use.
We have an obligation to ensure
that your personal information is accurate and up to date.
Please ask us to correct or
remove any information that you think is incorrect.
Marketing
We’d like to send you information
about our products and services and those of other
companies in the Luminous Living
Ltd group which may be of interest to you. If you agree to receive marketing
information, you may opt out at a later date.
You have a right at any time to
stop us from contacting you for marketing purposes or giving
your information to other members
of the group. If you no longer wish to be contacted for
marketing purposes, please
contact us by email or post.
What can you do if you are unhappy with how your
personal data is processed?
You also have a right to lodge a
complaint with the supervisory authority for data protection.
In the UK this is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
0303 123 1113 (local rate)
Changes to our privacy policy
We keep our privacy policy under
regular review. This privacy policy was last updated on
13th March 2025.
How to contact us
Please contact us if you have any
questions about our privacy policy or information we hold
about you: by email to info@luminousliving.co.uk
Or write to us at:
Data Controller (Charmaine
Davis)
Luminous Living
Ltd,
7 Rylands Rd,
Southend-on-Sea,
Essex
SS2 4LW