Data Protection Policy


Policy prepared by: Adepte T/A Spotstar Approved by board on: 1st May 2018 Next review date: 31st June 2019 Data Protection Registration Number (ico.): ZA265370

Adepte 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.

Why This Policy Exists

This data protection policy ensures Adepte – Owners and Operators of Spotstar:

  • 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 Data Protection Act 1998 describes how organisations – including Adepte – 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.

Adepte ensure that personal information is:

  1. processed fairly and lawfully
  2. obtained only for specific, lawful purposes
  3. adequate, relevant and not excessive
  4. accurate and kept up to date
  5. not to be held for any longer than necessary
  6. processed in accordance with the rights of data subjects
  7. protected in appropriate ways
  8. not to be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.


Policy Scope

This policy applies to:

  • The Head Office of Adepte Ltd
  • All branches of Adepte
  • All staff and volunteers of Adepte
  • All contractors, suppliers and other people working on behalf of Adepte

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • …plus any other information relating to individuals

Data Protection Risks

This policy helps to protect Adepte 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 company uses data relating to them.Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.


Everyone who works for or with Adepte has some responsibility for ensuring that 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 board of directors is ultimately responsible for ensuring that Adepte meets its legal obligations.
  • The Adepte Ltd Directors are responsible for:
    • Keeping the board updated about data protection responsibilities, risks and issues.
    • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
    • Arranging data protection training and advise 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 Adepte 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.
  • The Adepte Technical Director 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 third­party services the company is considering using to store or process data. For instance, cloud computing services.
  • The Adepte Services Director is responsible for:
    • Approving any data protection statements attached to communications such as emails and letters.
    • Addressing any data protection queries from other staff to ensure marketing initiatives abide by data protection principles.


  • 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.
  • Adepte 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 a nd 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 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.


These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot access 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 when 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 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.
  • Data should never be saved directly to laptops or other mobile devises like tablets or smart phones.
  • All servers and computers containing data should be protected by approved security software and a firewall.


The law requires Adepte 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 Adepte 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 additional data sets.
  • Staff should take every opportunity to ensure data is updated . For instance, by confirming a customer’s details when they call.
  • Adepte will make it easy for individuals to update the information Adepte hold about them. For instance, via the company website.
  • Data should be updated as inaccuracies are discovered. F or instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.


All individuals who are the subject of personal data held by Adepte 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.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should ideally be made by email to addressed to the Technical Director at Adepte, or in writing by post to 54 St James Street Liverpool L1 0AB.

Adepte will aim to provide the relevant data within 30 days.

The technical director will always verify the identity of anyone making a subject access request before handing over any information.


In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Adepte will disclose requested data. However, Adepte will ensure the request is legitimate, seeking assistance from the board and from the our legal advisers where necessary.


Adepte 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

Individual Consent

To provide an effective recruitment service it is necessary for Adepte Ltd to share part of your personal data stored in the spotstar system with contracted employers looking to recruit.

The data that is shared is specifically:

  • Your First Name
  • Your Contact Number
  • Your Work History
  • Your Training and Education
  • Your Profile Picture
  • Your Profile Videos

To indicate your consent for this information shared you are requested to activate the “share my profile” tab on your profile page. You can withdraw this consent at any time by deactivating the tab and your details will not be shared. Any other details such as home address, last name and email address will only be shared with your specific consent with employers on offer of interview and or employment.

Right to be informed

Your personal data is stored for as long as you give permission. You can choose to completely remove all of your personal data from the spotstar system by selecting the “delete account” tab located in your account settings. The system uses algorithms to automatically match your profile to recruiting employers, the decision to engage and or employ is not automated this decision rests solely with the individual and employer. You also have the right to lodge a complaint in the first instance by directly contacting the data controller at or directly to the Information Commissioner Office at

Right of access

All of your personal details held in the spotstar system is accessible to individuals at any time by logging in to the system using your personal username and password.

Right to rectification

You can update or amend your personal details in spotstar by logging into the system using your personal username and password.

Right to erasure

You can completely erase all of your personal data in the spotstar system, by logging into the system and selecting the “delete account” tab located in your account settings

Right to restrict processing

You can restrict the processing or sharing of your data at any time, there are two ways to do this, either:

Log into your spotstar account and deactivate the “share my profile” tab on the profile page


Log into your spotstar account and select the “deactivate account” tab in your account settings.


If you require clarity or further information, please contact Adepte on:

  • Email: