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RA_HO_09 — Confidential Data Handling

Document Information

Field Value
Document Reference RA_HO_09
Issue Date 04/07/2025
Next Review 04/07/2026
Assessed By Sean Ashton (HSQE Consultant)
Approved By Aaron Mason, Director
Classification Controlled

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Related: APP_07 Hazard Identification Log · APP_08 OHS Hazard Assessments Register

Task/Activity

Handling, storing, and disposing of confidential information

Location

All work locations including home offices

Persons at Risk

  • Client-facing staff
  • Data subjects
  • Company reputation
  • Regulatory compliance

Hazards and Controls

Hazard Existing Controls S L R Additional Controls S L R
Breach of client confidentiality Clear desk policy, locked storage 3 2 🟡 6 Enhanced training, audit programme 2 1 🟢 2
WIRS data exposure Access controls, training 3 2 🟡 6 Regular reviews, secure systems 2 1 🟢 2
Commercial sensitivity breach Confidentiality agreements, procedures 3 2 🟡 6 Secure disposal verification, monitoring 2 1 🟢 2
Paper document mishandling Lockable filing, shredding policy 2 2 🟢 4 Confidential waste bins, collection service 2 1 🟢 2
Screen privacy in public Privacy screens, awareness 2 3 🟡 6 Mandatory privacy filters, positioning guidance 2 1 🟢 2
Verbal disclosure Training, private spaces 3 2 🟡 6 Sound masking, meeting protocols 2 1 🟢 2
Device theft/loss Encryption, remote wipe 3 2 🟡 6 Device tracking, biometric locks 3 1 🟢 3
Printing errors Secure print release, collection 2 2 🟢 4 Pull printing, watermarking 2 1 🟢 2

PPE Requirements

  • Not applicable

Training Requirements

  • Data protection training
  • Confidentiality awareness
  • Secure disposal methods
  • GDPR requirements
  • Information classification
  • Clean desk procedures

Emergency Procedures

  • Data breach response
  • Containment procedures
  • Notification protocols
  • Investigation process
  • Remedial actions
  • Regulatory reporting

Monitoring

  • Disposal records
  • Incident tracking

Risk Assessment Summary

Risk Scoring Matrix

  • Severity (S): 1=Negligible, 2=Minor, 3=Serious, 4=Catastrophic
  • Likelihood (L): 1=Remote, 2=Unlikely, 3=Likely, 4=Almost Certain
  • Risk Rating: 🟢 Low (1-5), 🟡 Medium (6-11), 🔴 High (12-16)

Document Control

  • All risk assessments reviewed annually
  • Update following incidents or changes
  • Approved by senior management
  • Communicated to all relevant parties
  • APP_07 Hazard Identification Log
  • IMS Manual (MAN_01)
  • Safe Systems of Work
  • Method Statements
  • Training Matrix

Risk Scoring Matrix (4 × 4)

  • Severity (S): 1 = Negligible · 2 = Minor · 3 = Serious · 4 = Catastrophic
  • Likelihood (L): 1 = Remote · 2 = Unlikely · 3 = Likely · 4 = Almost Certain
  • Risk Rating (R = S × L): 🟢 Low (1-5) · 🟡 Medium (6-11) · 🔴 High (12-16)

This RA uses the same 4 × 4 matrix applied across APP_07, APP_08 and all sister RAs for auditor consistency.

How this document is approved

This document is maintained under AMWS's continuous-compliance model. Substantive revisions are reviewed and signed off by the Directors at the standing weekly Director / HSQE compliance call (Sean Ashton, Onyx + Leanne Mason). Currency, cross-references and minor edits are checked at the monthly Onyx site visit. The annual Management Review (September) provides the strategic-level confirmation. Compliance is therefore continuous, not gated on a single annual meeting.