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‘Data Controller’ is a person who, either alone or with others, controls the contents and use of
personal data

‘Data Processor’ is a person who processes personal information on behalf of a data controller but
does not include an employee of a data controller who processes such data in the course of his/her
employment.
‘Processing’ means performing any operation or set of operations on data, including:

• Obtaining, recording or keeping the data

• Collecting, organising, storing, altering or adapting the data

• Retrieving, consulting or using the data

• Disclosing the data or information by transmitting, disseminating or otherwise
making it available

• Aligning, combining, blocking, erasing or destroying the data

3.17.2 Practical Steps to Protect Data and Privacy

Data protection is everyone’s responsibility and listed below are some practical steps to
protect data and an individual’s right to privacy.

Practical steps for data protection;

• Personal information should not be deliberately or inadvertently viewed by uninvolved parties.
• Staff should operate a clear desk and counter policy at the end of each working day and when
away from the desk or the office for long periods
• Personal and sensitive records held on paper and/or on screens must be kept hidden from
customers and visitors to counters, stores and offices. Remember -
• Records (customer; client or employee files) containing personal information must never be left
unattended where they are visible or maybe accessed by unauthorised staff or members of the
public.
• If computers or VDUs are left unattended, staff must ensure that no personal information may
be observed or accessed by unauthorised staff or members of the public.
• The use of secured screen savers is advised to reduce the chance of casual observation.
• Rooms, cabinets or drawers in which personal records are stored should be locked when
unattended. A record tracing system should be maintained of files removed and/or returned.
• It is important to ensure that service user and/or staff information is not discussed in
inappropriate areas where it is likely to be overheard including conversations and telephone
calls.

Particular care should be taken in areas where the public may have access – for example a customer,
client or supplier’s representative allowed to wait behind the counter to meet a member of the
management team.

Never leave information/data unattended in company vans or private cars

• Staff must not leave laptops/portable electronic devices and/or files containing personal

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