Data protection policy
This Data Protection Policy complies with the EU’s General Data Protection Regulations (GDPR) and sets out how we handle the personal data of our customers, suppliers, employees, workers and other third parties regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other data subject. This Policy applies to all Company personnel and sets out what we expect from you in order for the Company to comply with applicable law. Your compliance with this Data Protection Policy is mandatory. Any breach of this Data Protection Policy may result in disciplinary action.
Data Protection Principles
We adhere to the principles relating to processing of personal data set out in the GDPR which require personal data to be:
Lawfulness, Fairness, Transparency
Personal data must be processed fairly and in a transparent manner in relation to the data subject.
You may only collect, process and share personal data fairly and lawfully and for specified purposes, some of which are set out below:
A data controller must only process personal data on the basis of one or more of the lawful bases set out in the GDPR, which include consent.
A data subject consents to processing of their personal data if they indicate agreement clearly either by a statement or positive action to the processing.
Consent requires affirmative action so silence, pre-ticked boxes or inactivity are not sufficient. If consent is given in a document which deals with other matters, then the consent must be kept separate from those other matters.
Data subjects must be easily able to withdraw consent to processing at any time and withdrawal must be promptly honoured.
Consent may need to be refreshed if you intend to process personal data for a different and incompatible purpose which was not disclosed when the data subject first consented.
Unless we can rely on another legal basis of processing, explicit consent is usually required for processing sensitive personal data, for automated decision-making and for cross border data transfers.
Usually we will be relying on another legal basis (and not require explicit consent) to process most types of sensitive data. Where explicit consent is required, you must issue a fair processing notice to the data subject to capture explicit consent.
You will need to evidence consent captured and keep records of all consents so that the Company can demonstrate compliance with consent requirements.
The GDPR requires data controllers to provide detailed, specific, information to data subjects depending on whether the information was collected directly from data subjects or from elsewhere. Such information must be provided through appropriate privacy notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a data subject can easily understand them.
Personal data must be collected only for specified, explicit and legitimate purposes. It must not be further processed in any manner incompatible with those purposes.
You cannot use personal data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the data subject of the new purposes and they have consented where necessary.
Personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
You must ensure that when personal data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company’s data retention guidelines.
Personal data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.
You must check the accuracy of any personal data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date personal data.
Personal data must not be kept in an identifiable form for longer than is necessary for
the purposes for which the data is processed.
You must not keep personal data in a form which permits the identification of the data
subject for longer than needed for the legitimate business purpose for which we
originally collected it including for the purpose of satisfying any legal, accounting or
You will take all reasonable steps to destroy or erase from our systems all personal
data that we no longer require in accordance with all the Company’s applicable
records retention policies. This includes requiring third parties to delete such data
You will ensure data subjects are informed of the period for which data is stored and
how that period is determined in any applicable privacy notice.
Security Integrity & Confidentiality
Reporting A Personal Data Breach
The GDPR requires data controllers to notify any personal data breach to the applicable regulator and in certain instances, the data subject.
The GDPR restricts data transfers to countries outside the EEA in order to ensure that the level of data protection afforded to individuals by the GDPR is not undermined.
You may only transfer Personal Data outside the EEA if one of the following conditions applies:
Data Subject’s Rights & Requests
Data subjects have rights when it comes to how we handle their personal data. These
include rights to:
The Data controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The data controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.
The GDPR requires us to keep full and accurate records of all our data processing activities.
Training & Audit
We are required to ensure all company personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.
We are subject to certain rules and privacy laws when marketing to our customers.
For example, a data subject’s prior consent is required for electronic direct marketing (for example, by email, text or automated call). the limited exception for existing customers known as “soft opt in” allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every
The right to object to direct marketing must be explicitly offered to the data subject in an intelligible manner so that it is clearly distinguishable from other information.
A data subject’s objection to direct marketing must be promptly honoured. if a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.
Sharing Personal Data
Generally, we are not allowed to share personal data with third parties unless certain safeguards and contractual arrangements have been put in place.
We may only share the personal data we hold with another employee, agent or representative of our company, if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions.