1 POLICY STATEMENT
The Mulberry Tree (hereinafter referred to as the “Company”)
needs to collect personal information to effectively carry out our everyday business functions and
activities and to provide the products and services defined by our business type. Such data is
collected from employees, customers, suppliers and clients and includes (but is not limited to), name,
address, email address, data of birth, IP address, identification numbers, private and confidential
information, sensitive information and bank/credit card details.
In addition, we may be required to collect and use certain types of personal information to comply
with the requirements of the law and/or regulations, however we are committed to processing all
personal information in accordance with the General Data Protection Regulation (GDPR), UK data
protection laws and any other relevant the data protection laws and codes of conduct (herein
collectively referred to as “the data protection laws”).
The Company has developed policies, procedures, controls and measures to ensure maximum and
continued compliance with the data protection laws and principles, including staff training,
procedure documents, audit measures and assessments. Ensuring and maintaining the security and
confidentiality of personal and/or special category data is one of our top priorities and we are proud
to operate a ‘Privacy by Design’ approach, assessing changes and their impact from the start and
designing systems and processes to protect personal information at the core of our business.
2 PURPOSE
The purpose of this policy is to ensure that the Company meets its legal, statutory and regulatory
requirements under the data protection laws and to ensure that all personal and special category
information is processed compliantly and in the individuals best interest.
The data protection laws include provisions that promote accountability and governance and as such
the Company has put comprehensive and effective governance measures into place to meet these
provisions. The aim of such measures is to ultimately minimise the risk of breaches and uphold the
protection of personal data. This policy also serves as a reference document for employees and
third-parties on the responsibilities of handling and accessing personal data and data subject
requests.
3 SCOPE
This policy applies to all staff within the Company (meaning permanent, fixed term, and temporary
staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and
agents engaged with the Company in the UK or overseas), and pertains to the processing of personal
information. Adherence to this policy is mandatory and non-compliance

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3.1 DEFINITIONS
• “Biometric data” means personal data resulting from specific technical processing relating to
the physical, physiological or behavioural characteristics of a natural person, which allow or
confirm the unique identification of that natural person, such as facial images or
dactyloscopic data.
• “Binding Corporate Rules” means personal data protection policies which are adhered to by
the Company for transfers of personal data to a controller or processor in one or more third
countries or to an international organisation.
• “Consent” of the data subject means any freely given, specific, informed and unambiguous
indication of the data subject’s wishes by which he or she, by a statement or by a clear
affirmative action, signifies agreement to the processing of personal data relating to him or
her.
• “Cross Border Processing” means processing of personal data which: –
o takes place in more than one Member State; or
o which substantially affects or is likely to affect data subjects in more than one
Member State
• “Data controller” means, the natural or legal person, public authority, agency or other body
which, alone or jointly with others, determines the purposes and means of the processing of
personal data; where the purposes and means of such processing are determined by Union
or Member State law, the controller or the specific criteria for its nomination may be
provided for by Union or Member State law.
• “Data processor” means a natural or legal person, public authority, agency or other body
which processes personal data on behalf of the controller.
• “Data protection laws” means for the purposes of this document, the collective description
of the GDPR, Data Protection Bill and any other relevant data protection laws that the
Company complies with.
• “Data subject” means an individual who is the subject of personal data
• “GDPR” means the General Data Protection Regulation (EU) (2016/679)
• “Genetic data” means personal data relating to the inherited or acquired genetic
characteristics of a natural person which give unique information about the physiology or the
health of that natural person and which result, in particular, from an analysis of a biological
sample from the natural person in question.
• “Personal data” means any information relating to an identified or identifiable natural
person (‘data subject’); an identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an identification number,
location data, an online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of that natural person.
• “Processing” means any operation or set of operations which is performed on personal data
or on sets of personal data, whether or not by automated means, such as collection,
recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation,
use, disclosure by transmission, dissemination or otherwise making available, alignment or

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combination, restriction, erasure or destruction.
• “Profiling” means any form of automated processing of personal data consisting of the use of
personal data to evaluate certain personal aspects relating to a natural person, in particular
to analyse or predict aspects concerning that natural person’s performance at work,
economic situation, health, personal preferences, interests, reliability, behaviour, location or
movements.
• “Recipient” means a natural or legal person, public authority, agency or another body, to
which the personal data are disclosed, whether a third party or not. However, public
authorities which may receive personal data in the framework of a particular inquiry in
accordance with Union or Member State law shall not be regarded as recipients; the
processing of those data by those public authorities shall be in compliance with the
applicable data protection rules according to the purposes of the processing.
• “Supervisory Authority” means an independent public authority which is established by a
Member State
• “Third Party” means a natural or legal person, public authority, agency or body other than
the data subject, under our direct authority
4 DATA PROTECTION BACKGROUND
The UK initially had The Data Protection Act 1984 in place to regulate the use of processed
information that related to individuals. However, in 1995 the introduction of EU Directive 95/46/EC
which set aims and requirements for member states on the protection of personal data when
processing or sharing, meant an updated Act was required.
The UK subsequently developed and enacted The Data Protection Act 1998 (DPA) to ensure that
British law complied with the EU Directive and to provide those with obligations under the Act, with
updated rules, requirements and guidelines for processing and sharing personal data.
2018 marks the 20th anniversary of the DPA enactment and whilst there have been periodical
additions or alterations to the Act, technology has advanced at a far faster rate, necessitating new
regulations for the current digital age. The past 20 years has also seen a vast increase in the number
of businesses and services operating across borders, further highlighting the international
inconsistency in Member States individual the data protection laws.
For this reason, in January 2012, the European Commission proposed a new regulation applying to
all EU Member States and bringing a standardised and consistent approach to the processing and
sharing of personal information across the EU.
4.1 NATIONAL DATA PROTECTION LAW
As the Company is in the UK, we are obligated under the GDPR and the UK’s Data Protection Bill that
implements the GDPR into UK law. Our data protection policies and procedures adhere to both the
GDPR and Data Protection Bill requirements, as applicable to our business type.

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4.2 GENERAL DATA PROTECTION REGULATION (GDPR)
The General Data Protection Regulation (GDPR) (EU)2016/679) was approved by the European
Commission in April 2016 and will apply to all EU Member States from 25th May 2018. As a
‘Regulation’ rather than a ‘Directive’, its rules apply directly to the Member States, replacing their
existing local the data protection laws and repealing and replacing Directive 95/46EC and its Member
State implementing legislation.
As the Company processes personal information regarding individuals (data subjects), we are
obligated under the General Data Protection Regulation (GDPR) to protect such information, and to
obtain, use, process, store and destroy it, only in compliance with the data protection laws and its
principles.
4.2.1 PERSONAL DATA
Information protected under the GDPR is known as “personal data” and is defined as: –
“Any information relating to an identified or identifiable natural person; an identifiable natural
person is one who can be identified, directly or indirectly, in particular by reference to an identifier
such as a name, an identification number, location data, an online identifier or to one or more factors
specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that
natural person.”
The Company ensures that a high level or care and measures are afforded to personal data falling
within the GDPR’s ‘special categories’ (previously sensitive personal data), due to the assumption
that this type of information could be used in a negative or discriminatory way and is of a sensitive,
personal nature to the persons it relates to.
In relation to the ‘Special categories of Personal Data’ the GDPR advises that: –
“Processing of personal data revealing racial or ethnic origin, political opinions, religious or
philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data
for the purpose of uniquely identifying a natural person, data concerning health or data concerning a
natural person’s sex life or sexual orientation shall be prohibited – unless one of the Article 9 clauses
applies.”
4.2.2 THE GDPR PRINCIPLES
Article 5 of the data protection laws requires that personal data shall be: –
a) processed lawfully, fairly and in a transparent manner in relation to the data subject
(‘lawfulness, fairness and transparency’)
b) collected for specified, explicit and legitimate purposes and not further processed in a
manner that is incompatible with those purposes; further processing for archiving purposes
in the public interest, scientific or historical research purposes or statistical purposes shall, in
accordance with Article 89(1), not be considered to be incompatible with the initial purposes
(‘purpose limitation’)

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c) adequate, relevant and limited to what is necessary in relation to the purposes for which they
are processed (‘data minimisation’)
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to
ensure that personal data that are inaccurate, having regard to the purposes for which they
are processed, are erased or rectified without delay (‘accuracy’)
e) kept in a form which permits identification of data subjects for no longer than is necessary for
the purposes for which the personal data are processed; personal data may be stored for
longer periods insofar as the personal data will be processed solely for archiving purposes in
the public interest, scientific or historical research purposes or statistical purposes in
accordance with Article 89(1) subject to implementation of the appropriate technical and
organisational measures required by this Regulation in order to safeguard the rights and
freedoms of the data subject (‘storage limitation’)
f) processed in a manner that ensures appropriate security of the personal data, including
protection against unauthorised or unlawful processing and against accidental loss,
destruction or damage, using appropriate technical or organisational measures (‘integrity
and confidentiality’).
Article 5(2) requires that ‘the controller shall be responsible for, and be able to demonstrate,
compliance with the data protection laws principles’ (‘accountability’) and requires that firms show
how they comply with the principles, detailing and summarising the measures and controls that they
have in place to protect personal information and mitigate the risks of processing.
4.3 THE INFORMATION COMMISSIONERS OFFICE (ICO)
The Information Commissioners Office (ICO) is an independent regulatory office who report directly
to Parliament and whose role it is to uphold information rights in the public interest. The legislation
they have oversight for includes: –
• The General Data Protection Regulation (GDPR) 25 May 2018
• The Privacy and Electronic Communication (EU Directive) Regulations 2003
• The Immigration Order 1972
The ICO’s mission statement is “to uphold information rights in the public interest, promoting
openness by public bodies and data privacy for individuals” and they can issue enforcement notices
and fines for breaches in any of the Regulations, Acts and/or Laws regulated by them.
Under the data protection laws the ICO, as the UK’s data protection authority (Supervisory
Authority), will have a similar role as previously, when it comes to oversight, enforcement and
responding to complaints with regards to the data protection laws and those firms located solely in
the UK.
The Company are registered with ICO and appear on the Data Protection Register as a controller and
processer of personal information.

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5 OBJECTIVES
We are committed to ensuring that all personal data processed by the Company is done so in
accordance with the data protection laws and its principles, along with any associated regulations
and/or codes of conduct laid down by the Supervisory Authority and local law. We ensure the safe,
secure, ethical and transparent processing of all personal data and have stringent measures to
enable data subjects to exercise their data protection rights.
The Company has developed the below objectives to meet our data protection obligations and to
ensure continued compliance with the regulatory requirements.
The Company ensures that: –
• We protect the rights of individuals with regards to the processing of personal information
• We develop, implement and maintain a data protection policy, procedure, audit plan and
training program for compliance with the data protection laws
• Every business practice, function and process carried out by the Company, is monitored for
compliance with the data protection laws and its principles
• Data is only processed where we have met the lawfulness of processing requirements
• We only process special category data in accordance with the GDPR regulations and in
compliance with the Data Protection Bill Schedule 1 requirements
• We record consent at the time it is obtained and evidence such consent to the Supervisory
Authority where requested
• All employees (including new starters and agents) are competent and knowledgeable about
their GDPR obligations and are provided with in-depth training in the data protection laws,
principles, regulations and how they apply to their role and our business
• Individuals feel secure when providing us with personal information and know that it will be
handled in accordance with their rights under the data protection laws
• We maintain a continuous program of monitoring, review and improvement with regards to
compliance with the data protection laws and to identify gaps and non-compliance before
they become a risk
• We monitor the Supervisory Authority, European Data Protection Board (EDPB) and GDPR
news and updates, to stay abreast of updates, notifications and additional requirements
• We have robust and documented Complaint Handling and Data Breach controls for
identifying, investigating, reviewing and reporting any breaches or complaints with regards to
data protection
• We have appointed a Carol Williams who takes responsibility for the overall supervision,
implementation and ongoing compliance with the data protection laws and performs specific
duties as set out under Article 37 of the GDPR.
• We have a dedicated Audit & Monitoring Program in place to perform regular checks and
assessments on how the personal data we process is obtained, used, stored and shared. The
audit program is reviewed against our data protection policies, procedures and the relevant
regulations to ensure continued compliance

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• We provide clear lines of reporting and supervision with regards to data protection
• We store and destroy all personal information, in accordance with the data protection laws
timeframes and requirements
• Any information provided to an individual in relation to personal data held or used about
them, with be provided in a concise, transparent, intelligible and easily accessible form, using
clear and plain language
• Employees are aware of their own rights under the data protection laws and are provided
with the Article 13 & 14 information disclosures
• Where applicable, we maintain records of processing activities in accordance with the Article
30 requirements
• We have developed and documented appropriate technical and organisational measures and
controls for personal data security
6 GOVERNANCE PROCEDURES
6.1 ACCOUNTABILITY & COMPLIANCE
Due to the nature, scope, context and purposes of processing undertaken by the Company, we carry
out frequent risk assessments and information audits to identify, assess, measure and monitor the
impact of such processing. We have also implemented adequate and appropriate technical and
organisational measures to ensure the safeguarding of personal data and compliance with the data
protection laws and any codes of conduct that we have obligations under.
We can demonstrate that all processing activities are performed in accordance with the data
protection laws and that we have in place robust policies, procedures, measures and controls for the
protection of data.
Our main governance objectives are to: –
• Educate senior management and employees about the requirements under the data
protection laws and the possible impact of non-compliance
• Provide a dedicated and effective data protection training program for all staff
• Identify key senior stakeholders to support the data protection compliance program
• Allocate responsibility for data protection compliance and ensure that the designated person
has sufficient access, support and budget to perform the role
• Identify, create and disseminate the reporting lines within the data protection governance
structure

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The technical and organisational measures that the Company has in place to ensure and demonstrate
compliance with the data protection laws, regulations and codes of conduct, are detailed in this
document and associated policies.
6.1.1 PRIVACY BY DESIGN
We operate a ‘Privacy by Design’ approach and ethos, with the aim of mitigating the risks associated
with processing personal data through prevention via our processes, systems and activities. We
therefore have additional measures in place to adhere to this ethos, including: –
Data Minimisation
Under Article 5 of the data protection laws, principle (c) advises that data should be ‘limited to what
is necessary’, which forms the basis of our minimal approach. We only ever obtain, retain, process
and share the data that is essential to carry out our services and legal obligations and we only keep if
for as long as is necessary.
Our systems, employees, processes and activities are designed to limit the collection of personal
information to that which is directly relevant and necessary to accomplish the specified purpose.
Data minimisation enables us to reduce data protection risks and breaches and supports our
compliance with the data protection laws.
Measures to ensure that only the necessary data is collected includes: –
• Electronic collection (i.e. forms, website, surveys etc) only have the fields that are relevant to
the purpose of collection and subsequent processing. We do not include ‘optional’ fields, as
optional denotes that it is not necessary to obtain
• Physical collection (i.e. face-to-face, telephone etc) is supported using scripts and internal
forms where the required data collection is ascertained using predefined fields. Again, only
that which is relevant and necessary is collected
• We have SLA’s and bespoke agreements in place with third-party controllers who send us
personal information (either in our capacity as a controller or processo

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Encryption
Although we class encryption as a form of pseudonymisation, we also utilise it as a secondary risk
prevention measure for securing the personal data that we hold. Encryption with a secret key is used
to make data indecipherable unless decryption of the dataset is carried out using the assigned key.
We utilise encryption via secret key for transferring personal data to any external party and provide
the secret key in a separate format. Where special category information is being transferred and/or
disclosed, the Data Protection Officer is required to authorise the transfer and review the encryption
method for compliance and accuracy.
Restriction
Our Privacy by Design approach means that we use company-wide restriction methods for all
personal data activities. Restricting access is built into the foundation of the Company’s processes,
systems and structure and ensures that only those with authorisation and/or a relevant purpose,
have access to personal information. Special category data is restricted at all levels and can only be
accessed by Richard Hurford and Alan Hecht
Hard Copy Data
Due to the nature of our business, it is sometimes essential for us to obtain, process and share
personal and special category information which is only available in a paper format without
pseudonymisation options (i.e. copies of patient records, hospital invoices or claims information).
Where this is necessary, we utilise a tiered approach to minimise the information we hold and/or the
length of time we hold it for. Steps include: –
• In the first instance, we always ask the initial data controller to send copies of any personal
information records directly to the data subject
• Where step 1 is not possible or feasible, we will obtain a copy of the data and if applicable
redact to ensure that only the relevant information remains (i.e. when the data is being
passed to a third-party for processing and not directly to the data subject)
• When only mandatory information is visible on the hard copy data, we utilise electronic
formats to send the information to the recipient to ensure that encryption methods can be
applied (i.e. we do not use the postal system as this can be intercepted).
• Recipients (i.e. the data subject, third-party processer) are reverified and their identity and
contact details checked
• The Data Protection Officer authorises the transfer and checks the file(s) attached and
encryption method and key
• Once confirmation has been obtained that the recipient has received the personal
information, where possible (within the legal guidelines and rules of the data protection
laws), we destroy the hard copy data and delete the sent message
• If for any reason a copy of the paper data must be retained by the Company, we use a physical
safe to store such documents as oppose to our standard archiving system

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6.1.2 INFORMATION AUDIT
To enable the Company to fully prepare for and comply with the data protection laws, we have
carried out a company-wide data protection information audit to better enable us to record,
categorise and protect the personal data that we hold and process.
The audit has identified, categorised and recorded all personal information obtained, processed and
shared by our company in our capacity as a controller/processor and has been compiled on a central
register which includes: –
• What personal data we hold
• Where it came from
• Who we share it with
• Legal basis for processing it
• What format(s) is it in
• Who is responsible for it?
• Disclosures and Transfers
6.2 LEGAL BASIS FOR PROCESSING (LAWFULNESS)
At the core of all personal information processing activities undertaken by the Company, is the
assurance and verification that we are complying with Article 6 of the data protection laws and our
lawfulness of processing obligations. Prior to carrying out any processing activity on personal
information, we always identify and establish the legal basis for doing so and verify these with the
regulations.
This legal basis is documented on our information audit register and where applicable, is provided to
the data subject and Supervisory Authority as part of our information disclosure obligations. Data is
only obtained, processed or stored when we have met the lawfulness of processing requirements,
where: –
• The data subject has given consent to the processing of their personal data for one or more
specific purposes
• Processing is necessary for the performance of a contract to which the data subject is party or
in order to take steps at the request of the data subject prior to entering into a contract
• Processing is necessary for compliance with a legal obligation to which we are subject
• Processing is necessary in order to protect the vital interests of the data subject or of another
natural person
• Processing is necessary for the performance of a task carried out in the public interest or in
the exercise of official authority vested in the Company
• Processing is necessary for the purposes of the legitimate interests pursued by the Company
or by a third party (except where such interests are overridden by the interests or
fundamental rights and freedoms of the data subject which require protection of personal
data, in particular where the data subject is a child).

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6.2.1 PROCESSING SPECIAL CATEGORY DATA
Special categories of Personal Data are defined in the data protection laws as: –
Processing of personal data revealing racial or ethnic origin, political opinions, religious or
philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data
for the purpose of uniquely identifying a natural person, data concerning health or data concerning a
natural person’s sex life or sexual orientation shall be prohibited – unless one of the Article 9 clauses
applies.
Where the Company processes any personal information classed as special category data or
information relating to criminal convictions, we do so in accordance with the data protection laws
Article 9 regulations and in compliance with the Data Protection Bill’s Schedule 1 Parts 1, 2, 3 & 4
requirements.
We will only ever process special category data where: –
• The data subject has given explicit consent to the processing of the personal
• Processing is necessary for the purposes of carrying out the obligations and exercising specific
rights of the controller or of the data subject in the field of employment and social security
and social protection law
• Processing is necessary to protect the vital interests of the data subject or of another natural
person where the data subject is physically or legally incapable of giving consent
• Processing is carried out in the course of its legitimate activities with appropriate safeguards
by a foundation, association or any other not-for-profit body with a political, philosophical,
religious or trade union aim
• Processing relates to personal data which are manifestly made public by the data subject
• Processing is necessary for the establishment, exercise or defence of legal claims or whenever
courts are acting in their judicial capacity
• Processing is necessary for reasons of substantial public interest
• Processing is necessary for the purposes of preventive or occupational medicine, for the
assessment of the working capacity of the employee, medical diagnosis, the provision of
health or social care or treatment or the management of health or social care systems and
services
• Processing is necessary for reasons of public interest in the area of public health
• Processing is necessary for archiving purposes in the public interest, scientific or historical
research purposes or statistical purposes in accordance with Article 89(1)
Schedule 1, Parts 1, 2 & 3 of The Data Protection Bill provide specific conditions and circumstances
when special category personal data can be processed and dictated the requirements that
organisations are obligated to meet when processing such data.
Where the Company processes personal data that falls into one of the above categories, we have the
specified provisions and measures in place prior to any processing. Measures include: –

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• Verifying our reliance on one of the data protection laws Article 9(1), and where applicable
The Data Protection Bill Sch.1, Pt.1, Pt.2 and/or Pt.3 conditions prior to processing
• Having an appropriate policy document in place when the processing is carried out, specifying
our: –
o procedures for securing compliance with the data protection laws principles
o policies as regards the retention and erasure of personal data processed in reliance on
the condition
o retention periods and reason (i.e. legal, statutory etc)
o procedures for reviewing and updating our policies in this area
Please refer to our Retention & Erasure Policy for further guidance and procedures.
6.2.2 RECORDS OF PROCESSING ACTIVITIES
As an organisation with less than 250 employees, the Company maintains records of all processing
activities where: –
• Processing personal data could result in a risk to the rights and freedoms of individual
• The processing is not occasional
• We process special categories of data or criminal convictions and offences
• Such records are maintained in writing, are provided in a clear and easy to read format and
are readily available to the Supervisory Authority upon request.
Acting in the capacity as a processor (or a representative), our internal records of the categories of
processing activities carried out on behalf of a controller, contain the following information: –
• The full name and contact details of the processor(s) and of each controller on behalf of
which the processor is acting, and, where applicable, of the controller’s or the processor’s
representative, and the data protection officer
• The categories of processing carried out on behalf of each controller
• Where applicable, transfers of personal data to a third country or an international
organisation (including the identification of that third country or international organisation
and where applicable, the documentation of suitable safeguards)
• A general description of the processing security measures as outlined in section 13 of this
document (pursuant to Article 32(1) of the data protection laws)
As part of our obligations under the UK’s Data Protection Bill, Sch.1, Pt.4, where we are required to
maintain a record of our processing activities in our capacity as a controller and are processing
special category or criminal conviction data, as specified in Sch.1, Pt.1-3 of the Bill, we also record
the below information on the register: –
• Which condition is relied on?
• How the processing satisfies Article 6 of the data protection laws (lawfulness of processing)

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• Whether the personal data is retained and erased in accordance with the policies described
in paragraph 30(b) of the DP Bill (and if not, the reasons for not following those policies).
6.3 CODES OF CONDUCT & CERTIFICATION MECHANISMS
The Company adheres to the data protection codes of conduct prepared by and are certified by the
Information Commissioner’s Office to demonstrate that we comply with the data protection laws
rules and principles.
These codes and certification mechanism are approved by the Supervisory Authority and have been
disseminated throughout the company to ensure competency and compliance from all staff.
The codes of conduct that we adhere to help us to: –
• Improve transparency and accountability
• Demonstrate to the public and Supervisory Authority that we meet the requirements of the
data protection law and that we can be trusted with personal data
• Mitigate against enforcement action(s)
• Improve standards by establishing best practice
• Carry out fair and transparent processing
• Ensure appropriate safeguards within the framework of personal data transfers to third
countries or international organisations
We submit to frequent and unscheduled monitoring and audits by the codes of conduct
association/trade body and by the data protection certification scheme and understand that where
we are deemed to be non-compliant in any area relating to the data protection laws, we may lose our
certification/seal of approval and/or the Supervisory Authority will be informed.
6.4 THIRD-PARTY PROCESSORS
The Company utilise external processors for certain processing activities (where applicable). We use
information audits to identify, categorise and record all personal data that is processed outside of the
company, so that the information, processing activity, processor and legal basis are all recorded,
reviewed and easily accessible. Such external processing includes (but is not limited to): –
• IT Systems and Services
• Legal Services
• Debt Collection Services
• Human Resources
• Credit Reference Agencies
• Direct Marketing Services
We have strict due diligence and Know Your Customer procedures and measures in place and
review, assess and background check all processors prior to forming a business relationship. We
obtain company documents, certifications, references and ensure that the processor is adequate,
appropriate and effective for the task we are employing them for.

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We audit their processes and activities prior to contract and during the contract period to ensure
compliance with the data protection regulations and review any codes of conduct that they are
obligated under to confirm compliance. The continued protection of the rights of the data subjects is
our priority when choosing a processor and we understand the importance of outsourcing
processing activities as well as our continued obligations under the data protection laws even when
a process is handled by a third-party.
We draft bespoke Service Level Agreements (SLAs) and contracts with each processor and among
other details, outlines: –
• The processors data protection obligations
• Our expectations, rights and obligations
• The processing duration, aims and objectives
• The data subjects’ rights and safeguarding measures
• The nature and purpose of the processing
• The type of personal data and categories of data subjects
Each of the areas specified in the contract are monitored, audited and reported on. Processors are
notified that they shall not engage another processor without our prior specific authorisation and
any intended changes concerning the addition or replacement of existing processors must be done in
writing, in advance of any such changes being implemented.
That contract or other legal act shall stipulate, in particular, that the processor: –
• Processes the personal data only on our documented instructions
• Seeks our authorisation to transfer personal data to a third country or an international
organisation (unless required to do so by a law to which the processor is subject)
• Shall inform us of any such legal requirement to transfer data before processing
• Ensures that persons authorised to process the personal data have committed themselves to
confidentiality or are under an appropriate statutory obligation of confidentiality
• Takes all measures to security the personal data at all times
• Respects, supports and complies with our obligation to respond to requests for exercising the
data subject’s rights
• Assists the Company in ensuring compliance with our obligations for data security, mitigating
risks, breach notification and privacy impact assessments
• When requested, deletes or returns all personal data to the Company after the end of the
provision of services relating to processing, and deletes existing copies where possible
• Makes available to the Company, all information necessary to demonstrate compliance with
the obligations set out here and in the contract
• Allows and supports audits, monitoring, inspections and reporting as set out in the contract
• Informs the Company immediately of any breaches, non-compliance or inability to carry out
their duties as detailed in the contract

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6.5 DATA RETENTION & DISPOSAL
The Company have defined procedures for adhering to the retention periods as set out by the
relevant laws, contracts and business requirements, as well as adhering to the data protection laws
requirement to only hold and process personal information for as long as is necessary. All personal
data is disposed of in a way that protects the rights and privacy of data subjects (e.g. shredding,
disposal as confidential waste, secure electronic deletion) and prioritises the protection of the
personal data at all times.
Please refer to our Data Retention & Erasure Policy for full details on our retention, storage, periods
and destruction processes.
7 DATA PROTECTION IMPACT ASSESSMENTS (DPIA)
Individuals have an expectation that their privacy and confidentiality will be upheld and respected
whilst their data is being stored and processed by the Company. We therefore utilise several
measures and tools to reduce risks and breaches for general processing, however when the
processing is likely to be high risk or cause significant impact to a data subject, we utilise
proportionate methods to map out and assess the impact ahead of time.
Where the Company must, or are considering carrying out processing that utilises new technologies,
and/or where there is a likelihood that such processing could result in a high risk to the rights and
freedoms of data subjects, we always carry out a Data Protection Impact Assessment (DPIA)
(sometimes referred to as a Privacy Impact Assessment).
Pursuant to Article 35(3) and Recitals 84, 89-96, we consider processing that is likely to result in a
high risk to include: –
• Systematic and extensive evaluation of personal aspects relating to natural persons which is
based on automated processing, including profiling, and on which decisions are based that
produce legal effects concerning the natural person or similarly significantly affect the natural
person(s)
• Processing on a large scale of special categories of data
• Processing on a large scale of personal data relating to criminal convictions and offences
• Systematic monitoring of a publicly accessible area on a large scale (i.e. CCTV)
• Where a processing operation is likely to result in a high risk to the rights and freedoms of an
individual
• Those involving the use of new technologies
• New processing activities not previously used
• Processing considerable amounts of personal data at regional, national or supranational level,
which could affect many data subjects
• Processing activities making it difficult for the data subject(s) to exercise their rights

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Carrying out DPIAs enables us to identify the most effective way to comply with our data protection
obligations and ensure the highest level of data privacy when processing. It is part of our Privacy by
Design approach and allows us to assess the impact and risk before carrying out the processing, thus
identifying and correcting issues at the source, reducing costs, breaches and risks.
The DPIA enables us to identify possible privacy solutions and mitigating actions to address the risks
and reduce the impact. Solutions and suggestions are set out in the DPIA and all risks are rated to
assess their likelihood and impact. The aim of solutions and mitigating actions for all risks is to
ensure that the risk is either: –
• Eliminated
• Reduced
• Accepted
8 DATA SUBJECT RIGHTS PROCEDURES
8.1 CONSENT & THE RIGHT TO BE INFORMED
The collection of personal and sometimes special category data is a fundamental part of the
products/services offered by the Company and we therefore have specific measures and controls in
place to ensure that we comply with the conditions for consent under the data protection laws.
The data protection law defines consent as; ‘Any freely given, specific, informed and unambiguous
indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative
action, signifies agreement to the processing of personal data relating to him or her’.
Where processing is based on consent, the Company have reviewed and revised all consent
mechanisms to ensure that: –
• Consent requests are transparent, using plain language and is void of any illegible terms,
jargon or extensive legal terms
• It is freely given, specific and informed, as well as being an unambiguous indication of the
individual’s wishes
• Consent is always given by a statement or a clear affirmative action (positive opt-in) which
signifies agreement to the processing of personal data
• Consent mechanisms are upfront, clear, granular (in fine detail) and easy to use and
understand
• Pre-ticked, opt-in boxes are never used
• Where consent is given as part of other matters (i.e. terms & conditions, agreements,
contracts), we ensure that the consent is separate from the other matters and is not be a
precondition of any service (unless necessary for that service)
• Along with our company name, we also provide details of any other third party who will use
or rely on the consent

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• Consent is always verifiable, and we have controls in place to ensure that we can
demonstrate consent in every case
• We keep detailed records of consent and can evidence at a minimum: –
o that the individual has consented to the use and processing of their personal data
o that the individual has been advised of our company name and any third party using
the data
o what the individual was told at the time of consent
o how and when consent was obtained
• We have ensured that withdrawing consent is as easy, clear and straightforward as giving it
and is available through multiple options, including: –
o Opt-out links in mailings or electronic communications
o Opt-out process explanation and steps on website and in all written communications
o Ability to opt-out verbally, in writing or by email
• Consent withdrawal requests are processed immediately and without detriment
• Controls and processes have been developed and implemented to refresh consent, especially
those relating to parental consents
• For special category data, the consent obtained is explicit (stated clearly and in detail, leaving
no room for confusion or doubt) with the processing purpose(s) always being specified
8.1.1 CONSENT CONTROLS
The Company maintain rigid records of data subject consent for processing personal data and are
always able to demonstrate that the data subject has consented to processing of his or her personal
data where applicable. We also ensure that the withdrawal of consent is as clear, simple and
transparent as it is to give consent.
Where the data subject’s consent is given in the context of a written declaration which also concerns
other matters, the request for consent is presented in a manner which is clearly distinguishable from
the other matters, in an intelligible and easily accessible form, using clear and plain language. All
such written declarations are reviewed and authorised by the Data Protection Officer prior to being
circulated.
The data protection laws states that where processing is based on consent and the personal data
relates to a child who is below the age of 16 years, such processing is only carried out by the
Company, where consent has been obtained by the holder of parental responsibility over the child.
The UK’s Data Protection Bill reduces this age to 13 years, as per Article 8(1) of the data protection
laws what advises that “Member States may provide by law for a lower age for those purposes
provided that such lower age is not below 13 years.”

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Consent to obtain, process, store and share (where applicable), is obtained by the Company through:
• Face-to-Face
• Telephone
• In Writing
• Email/SMS
• Electronic (i.e. via website form)
Points 1-4 are enforced using scripts, checklists, on-screen prompts and signed customer
agreements, to ensure that consent has been obtained and to remind employees of their additional
consent obligations, as below.
Electronic consent is always by a non-ticked, opt-in action (or double opt-in where applicable),
enabling the individual to provide consent after the below information has been provided. This is
then followed up with an email, SMS or written confirmation of the consent to process, store and
share the personal information.
Privacy Notices are used in all forms of consent and personal data collection, to ensure that we are
compliant in disclosing the information required in the data protection laws in an easy to read and
accessible format.
8.1.2 ALTERNATIVES TO CONSENT
The Company recognise that there are six lawful bases for processing and that consent is not always
the most appropriate option. We have reviewed all processing activities and only use consent as an
option where the individual has a choice.
When reviewing the processing activity for compliance with the consent requirements, we ensure
that none of the below are a factor: –
• Where we ask for consent, but would still process it even if it was not given (or withdrawn). If
we would still process the data under an alternative lawful basis regardless of consent, we
recognise it is not the correct lawful basis to use
• Where we ask for consent to process personal data as a precondition of a service we are
offering, it is not given as an option and consent is not appropriate
• Where there is an imbalance in the relationship, i.e. with employees
8.1.3 INFORMATION PROVISIONS
Where personal data is obtained directly from the individual (i.e. through consent, by employees,
written materials and/or electronic formats (i.e. website forms, subscriptions, email etc)), we provide
the below information in all instances, in the form of a consent/privacy notice: –
• The identity and the contact details of the controller and, where applicable, of the
controller’s representative
• The contact details of our data protection officer
• The purpose(s) of the processing for which the personal information is intended

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• The legal basis for the processing
• Where the processing is based on point (f) of Article 6(1) “processing is necessary for the
purposes of the legitimate interests pursued by the controller or by a third party”, details of
the legitimate interests
• The recipients or categories of recipients of the personal data (if applicable)
• If applicable, the fact that the Company intends to transfer the personal data to a third
country or international organisation and the existence/absence of an adequacy decision by
the Commission
o where the Company intends to transfer the personal data to a third country or
international organisation without an adequate decision by the Commission,
reference to the appropriate or suitable safeguards the Company has put into place
and the means by which to obtain a copy of them or where they have been made
available
• The period for which the personal data will be stored, or if that is not possible, the criteria
used to determine that period
• The existence of the right to request access to and rectification or erasure of, personal data
or restriction of processing concerning the data subject or to object to processing as well as
the right to data portability
• Where the processing is based on consent under points (a) of Article 6(1) or Article 9(2), the
existence of the right to withdraw consent at any time, without affecting the lawfulness of
processing based on consent before its withdrawal
• The right to lodge a complaint with the Supervisory Authority
• Whether providing personal data is a statutory or contractual requirement, or a requirement
necessary to enter into a contract, as well as whether the data subject is obliged to provide
the personal data and of the possible consequences of failure to provide such data
• The existence of any automated decision-making, including profiling, as referred to in Article
22(1) and (4) and explanatory information about the logic involved, as well as the significance
and the envisaged consequences of such processing for the data subject
The above information is provided to the data subject at the time the information is collected and
records pertaining to the consent obtained are maintained and stored for 6 years from the date of
consent, unless there is a legal requirement to keep the information longer.

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8.2 PRIVACY POLICY & NOTICES
8.2.1 PRIVACY POLICY
The Company recognises the difference between a Privacy Policy and a Privacy Notice (or statement)
and ensures that we meet the regulatory, legal and best practice requirements for both formats. For
the purposes of this document, we use the term Privacy Policy to provides the business, its staff and
any associated entities with our operational and organisational approach to protecting data and
complying with the General Data Protection Regulation (GDPR) and any relevant the data protection
laws.
This document is our Data Protection Policy and includes how we comply with the data protection
laws principles, the manner in which we process data, guidelines and procedures for ensuring that
data subjects can exercise their rights and our approach to data protection by design and default.
This policy provides detail on how we apply the principles, what procedures we follow in the
compliance with the Regulation and any specific individual and/or departmental responsibilities,
including those of the Data Protection Officer (DPO) and is fundamentally used as an internal
reference document.
We have a user-friendly version of our Privacy Policy on our website, which also includes details
about the cookies used on the site. The Privacy Policy on the site is in an easy to see and accessible
place and is in addition to our legally required Privacy Notice; more details of which are noted below.
8.2.2 PRIVACY NOTICE
Our Privacy Notice is separate from our Data Protection Policy and is provided to individuals at the
time we collect their personal data (or at the earliest possibility where that data is obtained
indirectly). Our Privacy Notice includes the Article 13 & 14 (section 8.1.3 of this policy) requirements
as set out in the data protection laws and provides individuals with all the necessary and legal
information about how, why and when we process their data, along with their rights and obligations.
Our Privacy Notice is designed to be a public declaration of how the Company applies the data
protection principles to data that we process. It is provided to all individuals whose data we process
(i.e. customers, employees, third-parties etc) and contains only the information specific to the
individual and as required by law. The notice is easily accessible, legible, jargon-free and is available
in several formats, dependant on the method of data collection: –
• Via our website
• Linked to or written in full in the footer of emails
• Worded in full in agreements, contracts, forms and other materials where data is collected in
writing or face-to-face
• In employee contracts and recruitment materials
• Verbally via telephone or face-to-face
• Via SMS
• Printed media, adverts and financial promotions

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• Digital Products/Services
• On Mobile Apps
• Automated phone service
With lengthy content being provided in the privacy notice and with informed consent being based on
its contents, we have tested, assessed and reviewed our privacy notice to ensure usability,
effectiveness and understanding.
We follow the below ICO preferred steps for testing, reviewing and auditing our privacy notice(s)
and opt-in consent formats prior to use and to record such assessments.
1. Privacy Notices are drafted by the Data Protection Officer using the data protection laws
requirements and with Supervisory Authority guidance
2. We utilise a select customer base to test the Privacy Notice in its varying formats and provide
a feedback form for completion, verifying the below points: –
a. How did you use the Privacy Notice (e.g. website, agreement, orally)?
b. Did you find the information in the Privacy Notice easy to read, understand and
access?
c. Did you gain a full understanding of how we intend to use your data, who it will be
shared with and what your rights are?
d. Did you feel confident in giving consent to use your personal data after reading the
notice information?
e. Was there anything you did not understand?
f. Did you find any errors?
g. What, if anything, would you like to see changed about the Privacy Notice?
3. All feedback responses are saved with a copy of the used Privacy Notice and improvements
are made and recorded where applicable
4. Re-testing is carried out on a new set of customers to ensure variety and independent
assessment and verification
5. After a successful test, the acceptable Privacy Notice is rechecked against the data protection
laws and Supervisory Authority regulations and guidelines to ensure it still complies and is
adequate and effective
6. The final Privacy Notice(s) are then authorised by Senior Management/Director(s) before
being rolled out
Where we rely on consent to obtain and process personal information, we ensure that it is: –
• Displayed clearly and prominently
• Asks individuals to positively opt-in
• Gives them sufficient information to make an informed choice
• Explains the different ways we will use their information
• Provides a clear and simple way for them to indicate they agree to different types of
processing

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• Includes a separate unticked opt-in box for direct marketing
8.3 PERSONAL DATA NOT OBTAINED FROM THE DATA SUBJECT
Where the Company obtains and/or processes personal data that has not been obtained directly
from the data subject, the Company ensures that the information noted in section 9.1.1 of this policy
is provided to the data subject within 30 days of our obtaining the personal data (except for advising
if the personal data is a statutory or contractual requirement).
In addition to the information provided to the data subject section of this policy, we also provide
information about: –
• The categories of personal data
• The source the personal data originated from and whether it came from publicly accessible
sources
Where the personal data is to be used for communication with the data subject, or a disclosure to
another recipient is envisaged, the information will be provided at the latest, at the time of the first
communication or disclosure. Where the Company intends to further process any personal data for a
purpose other than that for which it was originally obtained, we communicate this intention to the
data subject prior doing so and where applicable, process only with their consent.
Whilst we follow best practice in the provision of the information noted in the relevant section of
this policy, we reserve the right not to provide the data subject with the information if: –
• They already have it and we can evidence their prior receipt of the information
• The provision of such information proves impossible and/or would involve a disproportionate
effort
• Obtaining or disclosure is expressly laid down by Union or Member State law to which the
Company is subject and which provides appropriate measures to protect the data subject’s
legitimate interest
• Where the personal data must remain confidential subject to an obligation of professional
secrecy regulated by Union or Member State law, including a statutory obligation of secrecy
8.3.1 EMPLOYEE PERSONAL DATA
As per the data protection laws guidelines, we do not use consent as a legal basis for obtaining or
processing employee personal information. Our HR policies have been updated to ensure that
employees are provided with the appropriate information disclosure and are aware of how we
process their data and why.
All employees are provided with our Staff Handbook which informs them of their rights under the
data protection laws and how to exercise these rights.

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8.4 THE RIGHT OF ACCESS
We have ensured that appropriate measures have been taken to provide information referred to in
Articles 13 and 14 and any communication under Articles 15 to 22 and 34 (collectively, The Rights of
Data Subjects), relating to processing to the data subject in a concise, transparent, intelligible and
easily accessible form, using clear and plain language.
Such information is provided free of charge and is in writing, or by other means where authorised by
the data subject and with prior verification as to the subject’s identity (i.e. verbally, electronic).
Information is provided to the data subject at the earliest convenience, but at a maximum of 30 days
from the date the request is received. Where the retrieval or provision of information is particularly
complex or is subject to a valid delay, the period may be extended by two further months where
necessary. However, this is only done in exceptional circumstances and the data subject is kept
informed in writing throughout the retrieval process of any delays or reasons for delay.
Where we do not comply with a request for data provision, the data subject is informed within 30
days of the reason(s) for the refusal and of their right to lodge a complaint with the Supervisory
Authority.
8.4.1 SUBJECT ACCESS REQUEST
Where a data subject asks us to confirm whether we hold and process personal data concerning
him or her and requests access to such data; we provide them with: –
• The purposes of the processing
• The categories of personal data concerned
• The recipients or categories of recipient to whom the personal data have been or will be
disclosed
• If the data has or will be disclosed to a third countries or international organisations and the
appropriate safeguards pursuant to the transfer
• Where possible, the envisaged period for which the personal data will be stored, or, if not
possible, the criteria used to determine that period
• The existence of the right to request rectification or erasure of personal data or restriction of
processing of personal data concerning the data subject or to object to such processing
• The right to lodge a complaint with a Supervisory Authority
• Where personal data has not been collected by the Company from the data subject, any
available information as to the source and provider
• The existence of automated decision-making, including profiling and meaningful information
about the logic involved, as well as the significance and the envisaged consequences of such
processing for the data subject
Subject Access Requests (SAR) are passed to the Data Protection Officer as soon as received and a
record of the request is noted. The type of personal data held about the individual is checked against
our Information Audit to see what format it is held in, who else has it has been shared with and any

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specific timeframes for access.
SARs are always completed within 30-days and are provided free of charge. Where the individual
makes the request by electronic means, we provide the information in a commonly used electronic
format, unless an alternative format is requested.
Please refer to our external Subject Access Request Procedures for the guidelines on how an SAR can
be made and what steps we take to ensure that access is provided under the data protection laws.
8.5 DATA PORTABILITY
The Company provides all personal information pertaining to the data subject to them on request
and in a format, that is easy to disclose and read. We ensure that we comply with the data
portability rights of individuals by ensuring that all personal data is readily available and is in a
structured, commonly used and machine-readable format, enabling data subjects to obtain and
reuse their personal data for their own purposes across different services.
To ensure that we comply with Article 20 of the data protection laws concerning data portability, we
keep a commonly used and machine-readable format of personal information where the processing
is based on: –
• Consent pursuant to point (a) of Article 6(1)
• Consent pursuant to point (a) of Article 9(2)
• A contract pursuant to point (b) of Article 6(1); and
• the processing is carried out by automated means
Where requested by a data subject and if the criteria meet the above conditions, we will transmit
the personal data directly from the Company to a designated controller, where technically feasible.
We utilise the below formats for the machine-readable data: –
• HTML
• CSV
• XML
• RDF
• XHTML
All requests for information to be provided to the data subject or a designated controller are done so
free of charge and within 30 days of the request being received. If for any reason, we do not act in
responding to a request, we provide a full, written explanation within 30 days to the data subject or
the reasons for refusal and of their right to complain to the supervisory authority and to a judicial
remedy.
All transmission requests under the portability right are assessed to ensure that no other data
subject is concerned. Where the personal data relates to more individuals than the subject
requesting the data/transmission to another controller, this is always without prejudice to the rights
and freedoms of the other data subjects.

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8.6 RECTIFICATION & ERASURE
8.6.1 CORRECTING INACCURATE OR INCOMPLETE DATA
Pursuant to Article 5(d), all data held and processed by the Company is reviewed and verified as
being accurate wherever possible and is always kept up to date. Where inconsistencies are identified
and/or where the data subject or controller inform us that the data we hold is inaccurate, we take
every reasonable step to ensure that such inaccuracies are corrected with immediate effect.
The Data Protection Officer is notified of the data subjects request to update personal data and are
responsible for validating the information and rectifying errors where they have been notified. The
information is altered as directed by the data subject, with the information audit being checked to
ensure that all data relating to the subject is updated where incomplete or inaccurate. Once
updated, we add an addendum or supplementary statement where applicable.
Where notified of inaccurate data by the data subject, we will rectify the error within 30 days and
inform any third party of the rectification if we have disclosed the personal data in question to them.
The data subject is informed in writing of the correction and where applicable, is provided with the
details of any third-party to whom the data has been disclosed.
If for any reason, we are unable to act in response to a request for rectification and/or completion,
we always provide a written explanation to the individual and inform them of their right to complain
to the Supervisory Authority and to a judicial remedy.
8.6.2 THE RIGHT TO ERASURE
Also, known as ‘The Right to be Forgotten’, the Company complies fully with Article 5(e) and ensures
that personal data which identifies a data subject, is not kept longer than is necessary for the
purposes for which the personal data is processed.
All personal data obtained and processed by the Company is categorised when assessed by the
information audit and is either given an erasure date or is monitored so that it can be destroyed
when no longer necessary.
Please refer to our Data Retention & Erasure Policy for exact procedures on erasing data and
complying with the Article 17 requirements.

8.7 THE RIGHT TO RESTRICT PROCESSING
There are certain circumstances where the Company restricts the processing of personal
information, to validate, verify or comply with a legal requirement of a data subjects request.
Restricted data is removed from the normal flow of information and is recorded as being restricted
on the information audit.

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Any account and/or system related to the data subject of restricted data is updated to notify users of
the restriction category and reason. When data is restricted it is only stored and not processed in any
way.
The Company will apply restrictions to data processing in the following circumstances: –
• Where an individual contest the accuracy of the personal data and we are in the process
verifying the accuracy of the personal data and/or making corrections
• Where an individual has objected to the processing (where it was necessary for the
performance of a public interest task or purpose of legitimate interests), and we are
considering whether we have legitimate grounds to override those of the individual
• When processing is deemed to have been unlawful, but the data subject requests restriction
as oppose to erasure
• Where we no longer need the personal data, but the data subject requires the data to
establish, exercise or defend a legal claim
The Data Protection Officer reviews and authorises all restriction requests and actions and retains
copies of notifications from and to data subjects and relevant third-parties. Where data is restricted,
and we have disclosed such data to a third-party, we will inform the third-party of the restriction in
place and the reason and re-inform them if any such restriction is lifted.
Data subjects who have requested restriction of data are informed within 30 days of the restriction
application and are also advised of any third-party to whom the data has been disclosed. We also
provide in writing to the data subject, any decision to lift a restriction on processing. If for any
reason, we are unable to act in response to a request for restriction, we always provide a written
explanation to the individual and inform them of their right to complain to the Supervisory Authority
and to a judicial remedy.
8.8 OBJECTIONS AND AUTOMATED DECISION MAKING
Data subjects are informed of their right to object to processing in our Privacy Notices and at the
point of first communication, in a clear and legible form and separate from other information. We
provide opt-out options on all direct marketing material and provide an online objection form where
processing is carried out online. Individuals have the right to object to: –
• Processing of their personal information based on legitimate interests or the performance of
a task in the public interest/exercise of official authority (including profiling)
• Direct marketing (including profiling)
• Processing for purposes of scientific/historical research and statistics
Where the Company processes personal data for the performance of a legal task, in relation to our
legitimate interests or for research purposes, a data subjects’ objection will only be considered
where it is on ‘grounds relating to their particular situation’. We reserve the right to continue
processing such personal data where: –

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• We can demonstrate compelling legitimate grounds for the processing, which override the
interests, rights and freedoms of the individual
• The processing is for the establishment, exercise or defence of legal claims
Where we are processing personal information for direct marketing purposes under a previously
obtained consent, we will stop processing such personal data immediately where an objection is
received from the data subject. This measure is absolute, free of charge and is always adhered to.
Where a data subject objects to data processing on valid grounds, the Company will cease the
processing for that purpose and advise the data subject of cessation in writing within 30 days of the
objection being received.
We have carried out a system audit to identify automated decision-making processes that do not
involve human intervention. We also assess new systems and technologies for this same component
prior to implementation. the Company understands that decisions absent of human interactions can
be biased towards individuals and pursuant to Articles 9 and 22 of the data protection laws, we aim
to put measures into place to safeguard individuals where appropriate. Via our Privacy Notices, in
our first communications with an individual and on our website, we advise individuals of their rights
not to be subject to a decision when: –
• It is based on automated processing
• It produces a legal effect or a similarly significant effect on the individual
In limited circumstances, the Company will use automated decision-making processes within the
guidelines of the regulations. Such instances include: –
• Where it is necessary for entering into or performance of a contract between us and the
individual
• Where it is authorised by law (e.g. fraud or tax evasion prevention)
• When based on explicit consent to do so
• Where the decision does not have a legal or similarly significant effect on someone
Where the Company uses, automated decision-making processes, we always inform the individual
and advise them of their rights. We also ensure that individuals can obtain human intervention,
express their point of view and obtain an explanation of the decision and challenge it.
9 OVERSIGHT PROCEDURES
9.1 SECURITY & BREACH MANAGEMENT
Alongside our ‘Privacy be Design’ approach to protecting data, we ensure the maximum security of
data that is processed, including as a priority, when it is shared, disclosed and transferred. Our
Information Security Policy & Procedures provide the detailed measures and controls that we take
to protect personal information and to ensure its security from consent to disposal.

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We carry out information audits to ensures that all personal data held and processed by us is
accounted for and recorded, alongside risk assessments as to the scope and impact a data breach
could have on data subject(s). We have implemented adequate and appropriate technical and
organisational measures to ensure a level of security appropriate to the risk.
Whilst every effort and measure are taken to reduce the risk of data breaches, the Company has
dedicated controls and procedures in place for such situations, along with the notifications to be
made to the Supervisory Authority and data subjects (where applicable).
Please refer to our Data Breach Policy & Procedures for specific protocols.
9.2 PASSWORDS
Passwords are a key part of the Company protection strategy and are used throughout the company
to secure information and restrict access to systems. We use a multi-tiered approach which includes
passwords at user, management, device, system and network levels to ensure a thorough and
encompassing approach. Whilst passwords are also directly related to Information Security and
Access Control, the Company recognises to strong, effective and robust password controls and
measures are imperative to the protection and security of personal information.
Passwords afford a high level of protection to resources and data and are mandatory requirements
for all employees and/or third-parties who are responsible for one or more account, system or have
access to any resource that requires a password. Full procedures and guidelines for passwords,
access and security can be found in our Information Security Program.
10 TRANSFERS & DATA SHARING
The Company takes proportionate and effective measures to protect personal data held and
processed by us at all times, however we recognise the high-risk nature of disclosing and transferring
personal data and as such, place an even higher priority on the protection and security of data being
transferred. Data transfers within the UK and EU are deemed less of a risk than a third country or an
international organisation, due to the data protection laws covering the former and the strict
regulations applicable to all EU Member States.
Where data is being transferred for a legal and necessary purpose, compliant with all Articles in the
Regulation, we utilise a process that ensures such data is encrypted with a secret key and where
possible is also subject to our data minimisation methods. We use approved, secure methods of
transfer and have dedicated points of contact with each Member State organisation with whom we
deal. All data being transferred is noted on our information audit so that tracking is easily available,
and authorisation is accessible. The Data Protection Officer authorises all EU transfers and verifies
the encryption and security methods and measures.
Please refer to our International Data Transfer Procedures for further details.

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11 AUDITS & MONITORING
This policy and procedure document details the extensive controls, measures and methods used by
the Company to protect personal data, uphold the rights of data subjects, mitigate risks, minimise
breaches and comply with the data protection laws and associated laws and codes of conduct. In
addition to these, we also carry out regular audits and compliance monitoring processes that are
detailed in our Compliance Monitoring & Audit Policy & Procedure, with a view to ensuring that the
measures and controls in place to protect data subjects and their information, are adequate,
effective and compliant at all times.
The Data Protection Officer has overall responsibility for assessing, testing, reviewing and improving
the processes, measures and controls in place and reporting improvement action plans to the Senior
Management Team where applicable. Data minimisation methods are frequently reviewed and new
technologies assessed to ensure that we are protecting data and individuals to the best of our ability.
All reviews, audits and ongoing monitoring processes are recorded by the Data Protection Officer
and copies provided to Senior Management and are made readily available to the Supervisory
Authority where requested.
The aim of internal data protection audits is to: –
• Ensure that the appropriate policies and procedures are in place
• To verify that those policies and procedures are being followed
• To test the adequacy and effectiveness of the measures and controls in place
• To detect breaches or potential breaches of compliance
• To identify risks and assess the mitigating actions in place to minimise such risks
• To recommend solutions and actions plans to Senior Management for improvements in
protecting data subjects and safeguarding their personal data
• To monitor compliance with the data protection laws and demonstrate best practice
12 TRAINING
Through our strong commitment and robust controls, we ensure that all staff understand, have
access to and can easily interpret the data protection laws requirements and its Principles and that
they have ongoing training, support and assessments to ensure and demonstrate their knowledge,
competence and adequacy for the role. Our Training & Development Policy & Procedures and
Induction Policy detail how new and existing employees are trained, assessed and supported and
include: –
• GDPR Workshops & Training Sessions
• Assessment Tests
• Coaching & Mentoring
• 1:1 Support Sessions
• Scripts and Reminder Aids

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• Access to GDPR policies, procedures, checklists and supporting documents
Employees are continually supported and trained in the data protection laws requirements and out
own objectives and obligations around data protection.
13 PENALTIES
The Company understands our obligations and responsibilities under the data protection laws and
Supervisory Authority and comprehend the severity of any breaches under the Regulation. We
respect the Supervisory Authority’s authorisation under the legislation to impose and enforce fines
and penalties on us where we breach the regulations, fail to mitigate the risks where possible and
operate in a knowingly non-compliant manner.
Employees have been made aware of the severity of such penalties and their proportionate nature in
accordance with the breach. We recognise that: –
• Breaches of the obligations of the controller, the processor, the certification body and the
monitoring body, are subject to administrative fines up to €10,000,000 or 2 % of the total
worldwide annual turnover of the preceding financial year, whichever is higher.
• Breaches of the basic principles for processing, conditions for consent, the data subjects’
rights, the transfers of personal data to a recipient in a third country or an international
organisation, specific processing situations (Chapter IX) or non-compliance with an order by
the Supervisory Authority, are subject to administrative fines up to €20,000,000 or 4 % of the
total worldwide annual turnover of the preceding financial year, whichever is higher.
14 RESPONSIBILITIES
The Company has appointed a Data Protection Officer whose role it is to identify and mitigate any
risks to the protection of personal data, to act in an advisory capacity to the business, its employees
and upper management and to actively stay informed and up-to-date with all legislation and changes
relating to data protection. The DPO will work in conjunction with the Compliance Officer, IT
Manager and Training Officer to ensure that all processes, systems and staff are operating
compliantly and within the requirements of the data protection laws and its principles.
The DPO has overall responsibility for due diligence, privacy impact assessments, risk analysis and
data transfers where personal data is involved and will also maintain adequate and effective records
and management reports in accordance with the data protection laws and our own internal
objectives and obligations.
Staff who manage and process personal or special category information will be provided with
extensive data protection training and will be subject to continuous development support and
mentoring to ensure that they are competent and knowledge for the role they undertake.

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