We, at 2hD Ltd, 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 meet the company’s data protection standards — and to comply with the law.


  • About the context
  • People, risks and responsibilities
  • General staff guidelines
  • Subject access requests
  • Providing information 

About the context

Why this policy exists

This data protection policy ensures 2hD:

  • Complies with data protection law and follows good practice
  • Protects the rights of staff, customers 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 ‘General Data Protection Regulation (GDPR) (EU) 2016/679’ (GDPR) describes how organisations — including 2hD 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 GDPR is underpinned by a number of 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. This includes the right to erasure/to be forgotten where appropriate and theright to request copies of data that we hold pertaining to a data subject
  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
  9. Be obtained only with Explicit consent of the data subject
  10. Any data breaches will be reported to the ICO as appropriate.

People, risks and responsibilities

Policy scope

This policy applies to:

  • The head office of 2hD Ltd
  • All branches of 2hD Ltd, including 2hD Norway
  • All staff and volunteers of 2hD Ltd
  • All contractors, suppliers and other people working on behalf of 2hD Ltd

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outsideof the Data Protection Act 1998 or the GDPR 2018. 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 us from data security risks, including:

  • Breaches of confidentiality (e.g. information being given out inappropriately).
  • Failing to offer choice (e.g. all individuals should be free to choose how the company uses data relating to them).
  • Reputational damage (e.g. the company could suffer if hackers successfully gained access to sensitive data).


Everyone who works for or with us has some responsibility for ensuring data is collected, stored and handled appropriately. Whenever we handle personal data, we must ensure that it is handled and processed in line with this policy and data protection principles. However, the following people have key areas of responsibility:

The board of directors is responsible for:

  • Ensuring that 2hD Ltd ultimately meets its legal obligations.
  • Addressing any data protection queries from journalists or media outlets like newspapers.

The Data Protection Officer, is responsible for:

  • Keeping the board updated about data protection responsibilities, risks and issues.
  • Reviewing regularly all data protection procedures and related policies.
  • Arranging data protection training and advice for the people covered by this policy.
  • Handling data protection questions from staff and anyone else covered by this policy.
  • Dealing with requests from individuals to see the data we hold 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 that third-party partners, such as suppliers and sub-contractors, are complying with appropriate Data Protection regulations and that data shared for legitimate business reasons is treated safely and responsibly.
  • 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.

The IT manager, 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 any third-party services the company is considering using to store or process data (e.g. cloud computing services).

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.
  • We 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 company or externally.
  • Data should be regularly reviewed and updated if it is found to be out of date or if no longer required, it should be deleted and disposed of.
  • Employees should request help from 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 Data Protection Officer.

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:

  • 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.
  • If data is stored on removable media (like a 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 services.
  • 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.
  • 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 us 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.

Data accuracy

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

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 additional data sets.
  • Staff should take opportunity to ensure data is updated. For instance, by confirming a customer’s details when they communicate with us.
  • Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number or email address, it should be removed from the database.

Subject access requests

All individuals who are the subject of personal data held by 2hD Ltd 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 privacy@2hd.uk. The data controller will aim to provide the relevant data within 14 days. The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Providing information

We aim to ensure that individuals are aware that their data is being processed, and that they understand how the data is being used and how to exercise their rights. Have a look at our a privacy policy, setting out how data relating to individuals is used by the company.