Communications Policy3 November 2007

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Transcript of Communications Policy3 November 2007

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EXAMPLE COMMUNICATIONS POLICY

Instructions: This is an example communications polic! It ma "e suita"le #or use inour "usiness!

I# ou $ish to use the polic% ou $ill nee& to ma'e some amen&ments to it to suit thecircumstances o# our "usiness an& our attitu&e to ris'% so rea& it care#ull! Ita&&resses man issues% $hich is $h it is se(eral pa)es lon)% an& it ma "e that onlcertain parts #it our "usiness! You ma #eel that ou $ant to "rea' this up into a serieso# shorter policies* or ou ma #in& that parts shoul& "e &elete& or chan)e& su"stantiallto suit our circumstances!

+or example% our emploees ma ha(e use o# email "ut not o# the internet! Or ou manot $ish to a&&ress emploees, use o# "lo)s outsi&e $or'% or our "usiness ma or manot ha(e an intranet! In a&&ition% &epen&in) on the nature o# our "usiness% ou $illpro"a"l $ish to amen& certain points - #or example% $e re#er to ,in#ormin) our &i(isional mana)er, "ut our or)anisation ma not ha(e &i(isional mana)ers!

Loo' out #or sections in s.uare "rac'ets in particular - an& &on,t #or)et to &elete theseinstructions #rom the start o# the &ocument!

This &ocument is Copri)ht / Pinsent Masons 0112! It can "e use& internall in our or)anisation "ut must not "e sol& or &istri"ute& else$here!

I# ou $oul& li'e help #rom us to tailor this polic to our "usiness% or i# ou simpl $antsomethin) shorter% please contact us! Our contact &etails are at $$$!out3la$!com!

COMMUNICATIONS POLICY

4To "e issue& " emploer to sta## )o(ernin) authorise& use o# internet an& email

#acilities assumin) that limite& personal use is permitte&5

1. INT6O7UCTION

1.1 [XYZ CO'S] communications facilities are provided by [XYZ CO] and made available to

users for the purposes of the business. certain amount of limited and responsible

personal use by users is also permitted. ll use of our communications facilities is

!overned by the terms of this policy" and if our rules and procedures are not adhered

to" then use of our facilities may be curtailed or #ithdra#n and disciplinary action may

thereafter follo#. ny breach of this policy may lead to disciplinary action bein! ta$en

a!ainst you and serious breaches may lead to summary dismissal.

1.% t [XYZ CO]" communication plays an essential role in the conduct of our business.

&o# you communicate #ith people not only reflects on you as an individual but also

on us as an or!anisation. e value your ability to communicate #ith collea!ues"

[clients(customers] and business contacts" and #e invest substantially in information

technolo!y and communications systems #hich enable you to #or$ more efficiently.

e trust you to use them responsibly.

1.) *his policy applies to all individuals #or$in! for [XYZ CO] #ho use our  

communications facilities" #hether [directors ( departmental heads ( partners (

consultants]" full+time" part+time or fi,ed+term employees" trainees" contract staff"

temporary staff" a!ency or home #or$ers.

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1.- lthou!h the detailed discussion is limited to use of email and internet facilities" the

!eneral principles underlyin! all parts of this policy also apply to telephone

communications" fa, machines" copiers and scanners. ote that some elements of 

personal use of [XYZ CO'S] communications facilities are specifically addressed at

items ).)" -.) to -./" 0.- and 0./" and 1./. 2lease read this policy carefully.

%. 8ENE6AL P6INCIPLES

%.1 You must use [XYZ CO'S] information technolo!y and communications facilities

sensibly" [professionally]" la#fully" and consistently #ith your duties" #ith respect for 

your collea!ues and for [XYZ CO] and in accordance #ith this policy and [XYZ CO'S]

other rules and procedures.

%.% ll information relatin! to our [clients(customers] and our business operations is

confidential. You must treat our paper+based and electronic information #ith utmost

care.

%.) 3any aspects of communication are protected by intellectual property ri!hts #hich are

infrin!ed by copyin!. 4o#nloadin!" uploadin!" postin!" copyin!" possessin!"

processin! and distributin! material from the internet may be an infrin!ement of 

copyri!ht or of other intellectual property ri!hts.

%.- 2articular care must be ta$en #hen usin! email" [XYZ CO's] company blo! or internal

messa!e boards as a means of communication because all e,pressions of fact"

intention and opinion in an email may bind you and(or [XYZ CO] and can be produced

in court in the same #ay as other $inds of #ritten statements.

%./ *he advanta!e of the internet and email is that they are e,tremely easy and informal

#ays of accessin! and disseminatin! information" but this means that it is also easy to

send out ill+considered statements. ll messa!es sent on email systems or via the

internet should demonstrate the same professionalism as that #hich #ould be ta$en

#hen #ritin! a letter or a fa,. You must not use these media to do or say anythin!

#hich #ould be sub5ect to disciplinary or le!al action in any other conte,t such as

sendin! any discriminatory 6on the !rounds of a person's se," race" disability" a!e"

se,ual orientation" reli!ion or belief7" defamatory" or other unla#ful material 6for 

e,ample" any material that is desi!ned to be" or could be construed as" bullyin! or 

harassment by the recipient7. 8f you are in doubt about a course of action" ta$e advice

from your supervisin! [line mana!er(departmental head(partner].

). USE O+ ELECT6ONIC MAIL

).1 8enerall

).1.1 l#ays use the email template #hich contains the appropriate disclaimer 

notice from [XYZ CO] and do not amend this notice in any #ay.

).1.% 4o not amend any messa!es received and" e,cept #here specifically

authorised by the other person" do not access any other person9s in+bo, or 

other email folders nor send any email purportin! to come from another 

person.

).1.) 8t is !ood practice to re+read and chec$ an email before sendin!.

).1.- 8f you copy an email to others" it may breach the 4ata 2rotection ct if itreveals all the recipients' email addresses to each recipient 6e.!. in the case

of mar$etin! and mailin! lists7.

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8t can also breach duties of confidentiality 6e.!. in the case of internal emails

to members of a staff benefit scheme7. ccordin!ly" it may be appropriate to

use the ':cc' 6blind carbon copy7 field instead of the 'Cc' 6carbon copy7 field

#hen addressin! an email to more than one recipient. 8f in doubt" see$

advice from your [line mana!er(departmental head(partner].

).% 9usiness use

).%.1 ;ach business email should include the appropriate [XYZ CO] business

reference.

).%.% 8f the email messa!e or attachment contains information #hich is time+

critical" bear in mind that an email is not necessarily an instant

communication and consider #hether it is the most appropriate means of 

communication.

).%.) 8f you have sent an important document" al#ays telephone to confirm that

the email has been received and read.

).%.- 8n every instance" file a hard copy of any email 6includin! any attachments7

sent to or received from the [customer(client] before filin! or deletin! the

electronic copy. *he same applies to all internal email transmissions

concernin! [customer(client] matters.

).%./ 8n li!ht of the security ris$s inherent in some #eb+based email accounts" you

must not email business documents to your personal #eb+based accounts.

You may send documents to a [customer's(client9s] #eb+based account if you

have the [customer's(client9s] e,press #ritten permission to do so. [&o#ever"

under no circumstances should you send price sensitive or hi!hly

confidential documents to a [customer's(client9s] personal #eb+based email

account" even if the [customer(client] as$s you to do so.]

).%.< hen you need to #or$ on documents remotely they can be saved to a dis$

or retrieved over the internet [via XXX #ebsite]].

).) Personal Use

).).1 lthou!h [XYZ CO'S] email facilities are provided for the purposes of our 

business" #e accept that you may occasionally #ant to use them for your 

o#n personal purposes. *his is permitted on the condition that all the

procedures and rules set out in this policy are complied #ith. :e a#are"

ho#ever" that if you choose to ma$e use of our facilities for personalcorrespondence" you can e,pect very little privacy because [XYZ CO] may

need to monitor communications for the reasons !iven in item 0.1.

You #ill !reatly increase the privacy of any personal email by complyin! #ith

the procedures set out in item ).).) belo#.

).).% =nder no circumstances may [XYZ CO'S] facilities be used in connection

#ith the operation or mana!ement of any business other than that of [XYZ

CO] or a [customer(client] of [XYZ CO] unless e,press permission has been

obtained from your [line mana!er(departmental head(partner].

).).) ll personal email you send from [XYZ CO'S] facilities must be mar$ed2;>SO? in the sub5ect headin!" and all personal email sent or received

must be filed in a separate folder mar$ed @2ersonal@ in your inbo, should

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you #ish to retain it after readin!. Contact 8* Support if you need !uidance

on ho# to set up and use a personal folder. ll email contained in your inbo,

and your sent items bo, are deemed to be business communications for the

purposes of monitorin! 6see item 0.-7.

You must ensure that your personal email useA

6a7 does not interfere #ith the performance of your dutiesB

6b7 does not ta$e priority over your #or$ responsibilitiesB

6c7 is minimal and limited to ta$in! place substantially outside of 

normal #or$in! hours 6i.e. durin! any brea$s #hich you are entitled

to or before or after your normal hours of #or$7B

6d7 does not cause un#arranted e,pense or liability to be incurred by

[XYZ CO]B

6e7 does not have a ne!ative impact on [XYZ CO] in any #ayB and

6f7 is la#ful and complies #ith this policy.

).).- s #ith any correspondence made usin! [XYZ CO'S] electronic facilities" you

can delete personal email from the live system" but they #ill have been

copied 6perhaps many times7 onto the bac$up tapes and in that form #ill be

retained indefinitely. 8t #ould be a very difficult" costly and time+consumin!

e,ercise to sift all those tapes in order to delete an individual's personal

email" and if #e #ere to a!ree to attempt this" it #ould be at our 

convenience" and only on the basis that all the very considerable costs

involved #ere paid in advance by the person ma$in! the reuest.

).)./ :y ma$in! personal use of our facilities for sendin! and receivin! email you

si!nify your a!reement to abide by the conditions imposed for their use" and

si!nify your consent to [XYZ CO] monitorin! your personal email in

accordance #ith item 0 of this policy.

-. USE O+ INTE6NET AN7 INT6ANET

-.1 e trust you to use the internet sensibly. :ear in mind at all times that" #hen visitin! a

#ebsite" information identifyin! your 2C may be lo!!ed. *herefore any activity you

en!a!e in via the internet may affect [XYZ CO].

-.% e reco!nise the need for individuals to have to carry out some personal tas$s durin!

#or$in! hours" e.!. for internet ban$in! or online shoppin!" and this is permitted

sub5ect to the same rules as are set out for personal email use in item ).).- of this

policy. 8f these activities reuire additional soft#are to be installed onto your 2C then

you should submit a reuest to 8* Support #ho may be able to arran!e this for you.

[henever you need to do#nload soft#are to enable you to access an online service

you must obtain the e,press permission of [the 4irector of 8* or the *echnical Services

3ana!er] #ho #ill consider the reuest in line #ith [XYZ CO'S] policy.]

-.) You are stron!ly discoura!ed from providin! your [XYZ CO] email address #hen usin!

public #ebsites for non+business purposes" such as online shoppin!. *his must be

$ept to a minimum and done only #here necessary" as it results in you and [XYZ CO]receivin! substantial amounts of un#anted email.

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-.- [ccess to certain #ebsites is bloc$ed durin! normal #or$in! hours. 8f you have a

particular business need to access such sites" please contact [the 4irector of 8* or the

*echnical Services 3ana!er].]

You must notA

-.-.1 introduce pac$et+sniffin! or pass#ord+detectin! soft#areB

-.-.% see$ to !ain access to restricted areas of [XYZ CO'S] net#or$B

-.-.) access or try to access data #hich you $no# or ou!ht to $no# is confidentialB

-.-.- intentionally or rec$lessly introduce any form of spy#are" computer virus or 

other potentially malicious soft#areB nor 

-.-./ carry out any hac$in! activities

-.-.< [use [XYZ CO's] systems to participate in any internet chat room or post

messa!es on any e,ternal #ebsite" includin! any messa!e board or blo!"unless e,pressly permitted in #ritin! to do so by [XYZ CO]]

-./ Dor your information" breach of items -.-.1 to -.-.< 6inclusive7 above" #ould not only

contravene the terms of this policy but could in some circumstances also amount to

the commission of an offence under the Computer 3isuse ct 100" #hich creates the

follo#in! offencesA

-./.1 unauthorised access to computer material i.e. hac$in!B

-./.% unauthorised modification of computer materialB and

-./.) unauthorised access #ith intent to commit or facilitate the commission of 

further offences.

/. MISUSE O+ 4XY CO,S5 +ACILITIES AN7 SYSTEMS

/.1 3isuse of [XYZ CO's] facilities and systems" includin! its telephone" email and internet

systems" in breach of this policy #ill be treated seriously and dealt #ith in accordance

#ith [XYZ CO's] disciplinary procedure. 8n particular" vie#in!" accessin!" transmittin!"

postin!" do#nloadin! or uploadin! any of the follo#in! materials in the follo#in! #ays"

or usin! any of [XYZ CO's] facilities" #ill amount to !ross misconduct capable of 

resultin! in summary dismissal 6this list is not e,haustive7A

/.1.1 material #hich is se,ist" racist" homophobic" ,enophobic" porno!raphic"

paedophilic or similarly discriminatory and(or offensiveB

/.1.% offensive" obscene" dero!atory or criminal material or material #hich is liable

to cause embarrassment to [XYZ CO] and any of its staff or its

[customers(clients] or brin! the reputation of [XYZ CO] and any of its staff or 

its [customers(clients] into disreputeB

/.1.) any defamatory material about any person or or!anisation or material #hich

includes statements #hich are untrue or of a deceptive natureB

/.1.- any material #hich" by intent or other#ise" harasses the recipientB

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/.1./ any other statement #hich is desi!ned to cause annoyance" inconvenience

or an,iety to anyoneB

/.1.< any material #hich violates the privacy of others or unfairly criticises or 

misrepresents othersB

/.1.E confidential information about [XYZ CO] and any of its staff or [customers(clients]B

/.1.F any other statement #hich is li$ely to create any liability 6#hether criminal or 

civil" and #hether for you or [XYZ CO]7B

/.1.0 material in breach of copyri!ht and(or other intellectual property ri!htsB

/.1.1 online !amblin!B or 

/.1.11 unsolicited commercial or advertisin! material" chain letters or other 5un$

mail of any $ind.

8f [XYZ CO] has evidence of the e,amples of misuse set out above it

reserves the ri!ht to underta$e a more detailed investi!ation in accordance

#ith its disciplinary procedures.

<. SYSTEM SECU6ITY

<.1 Security of our 8* systems is of paramount importance. e o#e a duty to all of our 

[customers(clients] to ensure that all of our business transactions are $ept confidential.

8f at any time #e need to rely in court on any information #hich has been stored or 

processed usin! our 8* systems it is essential that #e are able to demonstrate the

inte!rity of those systems. ;very time you use the system you ta$e responsibility for 

the security implications of #hat you are doin!.

<.% [XYZ CO'S] system or euipment must not be used in any #ay #hich may cause

dama!e" or overloadin! or #hich may affect its performance or that of the internal or 

e,ternal net#or$.

<.) Geep all confidential information secure" use it only for the purposes intended and do

not disclose it to any unauthorised third party.

<.- Geep your system pass#ords safe. 4o not disclose them to anyone. *hose #ho have

a le!itimate reason to access other users' inbo,es must be !iven permission from that

other user. 8* Support #ill provide !uidance on ho# to do this8f you have disclosed

your pass#ord to anyone else 6e.!. in response to a reuest from the 8* staff7 ensure

that you chan!e your pass#ord once the 8* staff no lon!er need it. Contact 8* Support

for !uidance on ho# to do this.

<./ [8f a document is hi!hly commercially confidential or price sensitive" you should mar$ it

as @private and confidential@ and pass#ord+protect the document itself. :ear in mind

that documents #hich are O* mar$ed @private and confidential@ can be accessed by

all users of the net#or$.]

<.< [Copies of confidential information should be printed out only as necessary" retrieved

from the printer immediately" and stored or destroyed in an appropriate manner.]

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<.E You should not do#nload or install soft#are from e,ternal sources #ithout havin! first

received the necessary authorisation from [the 8* department(line

mana!er(departmental head(partner].

<.F o e,ternal device or euipment" includin! discs and other data stora!e devices"

should be run on or connected to [XYZ CO's] systems #ithout the prior notification to

and approval of [the 8* department(line mana!er(departmental head(partner]

<.0 You should al#ays e,ercise caution #hen openin! emails from un$no#n e,ternal

sources or #here" for any reason" an email appears suspicious. [*he 8*

department(line mana!er(departmental head(partner] should be informed immediately

in such circumstances.

E. ;O6<IN8 6EMOTELY

E.1 *his part of the policy and the procedures in it apply to your use of our systems" to

your use of our laptops" and also to your use of your o#n computer euipment or 

other computer euipment 6e.!. client9s euipment7 #henever you are #or$in! on

[XYZ CO'S] business a#ay from [XYZ CO'S] premises 6#or$in! remotely7.

hen you are #or$in! remotely you mustA

E.1.1 pass#ord protect any #or$ #hich relates to [XYZ CO'S] business so that no

other person can access your #or$B

E.1.% position yourself so that your #or$ cannot be seen by any other personB

E.1.) ta$e reasonable precautions to safe!uard the security of our euipment" and

$eep your pass#ords secretB

E.1.- inform the police and our 8* department 6as appropriate7 as soon as possible

if either a [XYZ CO] laptop in your possession or any computer euipment

on #hich you do [XYZ CO'S] #or$" even if this is personal 8* euipment" has

been lost or stolenB and

E.1./ ensure that any #or$ #hich you do remotely is saved on [XYZ CO'S] system

or is transferred to our system as soon as reasonably practicable.

E.% 2oc$et computers" mobile phones and similar hand+held devices are easily lost or 

stolen so you must pass#ord+protect access to any such devices used by you on

#hich is stored any personal data of #hich [XYZ CO] is a data controller or any

information relatin! our business" our clients or their business.

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F. PE6SONAL 9LO8S AN7 ;E9SITES

F.1 *his part of the policy and procedures in it apply to content that you publish on the

internet 6e.!. your contributions to blo!s" messa!e boards and social net#or$in! or 

content+sharin! sites7 even if created" updated" modified or contributed to outside of 

#or$in! hours or #hen usin! personal 8* systems.

F.% [XYZ CO] reco!nise that in your o#n private time you may #ish to publish content on

the internet. Dor the avoidance of doubt" such activities are e,pressly prohibited durin!

#or$ time or usin! [XYZ CO's] systems.

F.) 8f you post any content to the internet" #ritten" vocal or visual" #hich identifies" or 

could identify" you as a member of [XYZ CO] staff and(or you discuss your #or$ or 

anythin! related to [XYZ CO] or its business" customers or staff" [XYZ CO] e,pects

you" at all times" to conduct yourself appropriately and in a manner #hich is consistent

#ith your contract of employment and #ith [XYZ CO's] policies and procedures. 8t

should be noted that simply revealin! your name or a visual ima!e of yourself could

be sufficient to identify you as an individual #ho #or$s for [XYZ CO].

F.- 8f you already have a personal blo! or #ebsite #hich indicates in any #ay that you

#or$ for [XYZ CO] you should report this to your [line mana!er(departmental

head(partner].

F./ 8f you intend to create a personal blo! or #ebsite that #ill say that you #or$ for [XYZ

CO]" or in any #ay could identify you as someone #ho #or$s for [XYZ CO] then you

should report this to your [line mana!er(departmental head(partner].

F.< 8f a blo! postin! clearly identifies that you #or$ for [XYZ CO] and you e,press any

idea or opinion then you should add a disclaimer such as @these are my o#n personal

vie#s and not those of [XYZ CO]@.

F.E *he follo#in! matters #ill be treated as !ross misconduct capable of resultin! in

summary dismissal 6this list is not e,haustive7A

F.E.1 >evealin! confidential information about [XYZ CO] in a personal online

postin!. *his mi!ht include revealin! information relatin! to [XYZ CO's]

clients" business plans" policies" staff" financial information or internal

discussions. Consult your mana!er if you are unclear about #hat mi!ht be

confidential.

F.E.% Criticisin! or embarrassin! [XYZ CO]" its clients or its staff in a public forum

6includin! any #ebsite7. You should respect the [corporate] reputation of [XYZ CO] and the privacy and feelin!s of others at all times. 8f you have a

!enuine complaint to ma$e about a collea!ue or #or$place matter the

correct procedure is to raise a !rievance usin! [XYZ CO's] !rievance

procedure.

F.E.) [ccessin! or updatin! a personal blo! or #ebsite from [XYZ CO's]

computers or durin! #or$ time.]

F.F 8f you thin$ that somethin! on a blo! or a #ebsite could !ive rise to a conflict of 

interest and in particular concerns issues of impartiality or confidentiality reuired by

your role then this must be discussed #ith your [line mana!er(departmental

head(partner].

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F.0 8f someone from the media or press contacts you about your online publications that

relate to [XYZ CO] you should tal$ to your [line mana!er(departmental head(partner]

before respondin! and [XYZ CO's] press office must be consulted.

F.1 Online publications #hich do not identify the author as a member of [XYZ CO] staff 

and do not mention [XYZ CO] and are purely concerned #ith personal matters #ill

normally fall outside the scope of [XYZ CO's] communications policy.

0. MONITO6IN8 O+ COMMUNICATIONS 9Y 4XY CO5

0.1 [XYZ CO] is ultimately responsible for all business communications but sub5ect to that

#ill" so far as possible and appropriate" respect your privacy and autonomy #hile

#or$in!. [XYZ CO] may monitor your business communications for reasons #hich

includeA

0.1.1 providin! evidence of business transactionsB

0.1.% ensurin! that [XYZ CO'S] business procedures" policies and contracts #ith

staff are adhered toB

0.1.) complyin! #ith any le!al obli!ationsB

0.1.- monitorin! standards of service" staff performance" and for staff trainin!B

0.1./ preventin! or detectin! unauthorised use of [XYZ CO'S] communications

systems or criminal activitiesB and

0.1.< maintainin! the effective operation of [XYZ CO'S] communications systems.

0.% [XYZ CO] #ill monitor telephone" email and internet traffic data 6i.e. sender" receiver"

sub5ectB non+business attachments to email" numbers called and duration of callsB

domain names of #ebsites visited" duration of visits" and files do#nloaded from the

internet7 at a net#or$ level 6but coverin! both personal and business communications7

for the purposes specified at item 0.1. Dor the purposes of your maintenance of your 

o#n personal privacy" you need to be a#are that such monitorin! mi!ht reveal

sensitive personal data about you. Dor e,ample" if you re!ularly visit #ebsites #hich

detail the activities of a particular political party or reli!ious !roup" then those visits

mi!ht indicate your political opinions or reli!ious beliefs. :y carryin! out such activities

usin! [XYZ CO'S] facilities you consent to our processin! any sensitive personal data

about you #hich may be revealed by such monitorin!.

0.) Sometimes it is necessary for [XYZ CO] to access your business communications

durin! your absence" such as #hen you are a#ay because you are ill or #hile you are

on holiday. =nless your mailbo, settin!s are such that the individuals #ho need to do

this already have permission to vie# your inbo," access #ill be !ranted only #ith the

permission of one of the persons authorised to !rant such access [in accordance #ith

our policy @ccess to 3ailbo,es@].

0.- ny emails #hich are not stored in your @2ersonal@ folder in your mailbo, and #hich

are not mar$ed 2;>SO? in the sub5ect headin! #ill be treated" for the purpose of 

0

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availability for monitorin!" as business communications since #e #ill have no #ay of 

$no#in! that they #ere intended to be personal. *herefore you must set up a rule to

automate the routin! of personal email to your personal folder H as$ 8* Support for 

!uidance on ho# to do this. Durthermore" there is a ris$ that any person authorised to

access your mailbo, may have their o#n previe# pane option as a default settin!"

#hich #ould reveal the content of any of your personal email not filed in your 

@2ersonal@ folder" #hether or not such email are mar$ed 2;>SO?. 8t is up to you to

prevent the inadvertent disclosure of the content of personal email by filin! your 

personal email in accordance #ith this policy. 8n particular" you are responsible to

anybody outside [XYZ CO] #ho sends to you" or receives from you" a personal email"

for the conseuences of any breach of their privacy #hich may be caused by your 

failure to file your personal email. 

0./ 8n certain very limited circumstances #e may" sub5ect to compliance #ith any le!al

reuirements" access email mar$ed 2;>SO?. ;,amples are #hen #e have

reasonable suspicion that they may reveal evidence of unla#ful activity" includin!

instances #here there may be a breach of a contract #ith [XYZ CO].

0.< [ll incomin! email are scanned by [XXX] on behalf of [XYZ CO]" usin! virus+chec$in!

soft#are. *he soft#are #ill also bloc$ unsolicited mar$etin! email 6spam7 and email

#hich have potentially inappropriate attachments. 8f there is a suspected virus in an

email #hich has been sent to you" the sender #ill automatically be notified and you #ill

receive notice that the email is not !oin! to be delivered to you because it may contain

a virus.]

1. 7ATA P6OTECTION

1.1 s a member of [XYZ CO] #ho uses our communications facilities" you #ill inevitably

be involved in processin! personal data for [XYZ CO] as part of your 5ob. 4ata

protection is about the privacy of individuals" and is !overned by the 4ata 2rotection ct 100F. *his ct defines" amon! others" terms as follo#sA

1.1.1 @data@ !enerally means information #hich is computerised or in a structured

hard copy formB

1.1.% @personal data@ is data #hich can identify someone" such as a name" a 5ob

title" a photo!raphB

1.1.) @processin!@ is anythin! you do #ith data H 5ust havin! data amounts to

processin!B and

1.1.- @data controller@ is the person #ho controls the purposes and manner of processin! of personal data H this #ill be [XYZ CO]" in the case of personal

data processed for the business.

1.% henever and #herever you are processin! personal data for [XYZ CO] you must

$eep it secret" confidential and secure" and you must ta$e particular care not to

disclose them to any other person 6#hether inside or outside [XYZ CO]7 unless

authorised to do so. 4o not use any such personal data e,cept as authorised by [XYZ

CO] for the purposes of your 5ob. 8f in doubt !et help from our 4ata 2rotection Officer 

or your [line mana!er(departmental head(partner].

1.) *he 4ata 2rotection ct !ives every individual the ri!ht to see all the information #hich

any data controller holds about them. :ear this in mind #hen recordin! personalopinions about someone" #hether in an email or other#ise. 8t is another reason #hy

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personal remar$s and opinions must be made or !iven responsibly" and they must be

relevant and appropriate as #ell as accurate and 5ustifiable.

1.- Dor your information" section // of the 4ata 2rotection ct provides that it is a criminal

offence to obtain or disclose personal data #ithout the consent of the data controller.

@Obtainin!@ here includes the !atherin! of personal data by employees at #or$ #ithout

the authorisation of the employer. You may be committin! this offence if #ithout

authority of [XYZ CO]A you e,ceed your authority in collectin! personal dataB you

access personal data held by [XYZ CO]B to control it or you pass them on to someone

else 6#hether inside or outside [XYZ CO]7.

1./ hile [XYZ CO] is a data controller of all personal data processed for the purposes of 

our business" you #ill be a data controller of all personal data processed in any

personal email #hich you send or receive. =se for social" recreational or domestic

purposes attracts a #ide e,emption under the 4ata 2rotection ct" but if" in breach of 

this policy" you are usin! our communications facilities for the purpose of a business

#hich is not [XYZ CO'S] business" then you #ill ta$e on e,tensive personal liability

under the 4ata 2rotection ct.

1.< *o help you understand and comply #ith [XYZ CO'S] obli!ations as a data controller 

under the 4ata 2rotection ct you may be offered" and you may also reuest" trainin!.

henever you are unsure of #hat is reuired or you other#ise need !uidance in data

protection" you should consult our 4ata 2rotection Officer [or any member of the data

protection team]. [[XYZ CO'S] privacy statements and information about our data

protection policies can be found [on the XYZ CO intranet]].

11. COMPLIANCE ;IT= T=IS POLICY

11.1 Dailure to comply #ith this policy may result in disciplinary action bein! ta$en a!ainst

you under [XYZ CO'S] disciplinary procedures" #hich may include summary dismissal"and(or in the #ithdra#al of permission to use the firm's euipment for personal

purposes. 8f there is anythin! in this policy that you do not understand" please discuss

it #ith your [line mana!er(departmental head(partner].

11.% 2lease note that the procedures and policies outlined in this policy" and in any related

policy" may be revie#ed or chan!ed at any time. You #ill be alerted to important

chan!es [and updates #ill be published on our intranet].

Polic e&ition: No(em"er 0112

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