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Privacy Policy - Privacy matters to us


Privacy Policy and GDPR Regulation


The EU General Data Protection Regulation (GDPR) came into force across the European Union on 25th May 2018 and making significant changes

to data protection law,  Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the needs of the digital

age. The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border

processing. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more 

consistent rights to access and control their personal information.

Our Commitment  (we or us or our) are committed to ensuring the security and protection of the personal information that we process, and to provide

a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies

with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to 

meet the demands of the GDPR and the United Kingdoms Data Protection Bill/United Kingdoms DP law  are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective,

fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance

have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls

and measures to ensure maximum and ongoing compliance.  already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant

with the GDPR by 25th May 2018. Our preparation includes: 

Policies & Procedures “ revising/implementing new data protection policies and procedures to meet the requirements and standards of the GDPR and

any relevant data protection laws, including:“

Data Protection our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the 

GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations

and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.

Data Retention & Erasure “ we have updated our retention policy and schedule to ensure that we meet the ˜data minimisation and storage limitation 

principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place 

to meet the new ˜Right to Erasure obligation and are aware of when this and other data subjects rights apply; along with any exemptions, response 

timeframes and notification responsibilities.

Data Breaches our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal 

data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting

lines and steps to follow.

Subject Access Request (SAR) we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested 

information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing 

an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, 

consistent and adequate.

Privacy Notice/Policy we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we

process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding 

measures are in place to protect their information.

Obtaining Consent we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are 

providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent 

processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and

access way to withdraw consent at any time.

Direct Marketing we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; 

a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.


Data Subject Rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access

information via our website of an individuals right to access any personal information that  processes about them and to request

information about: 

What personal data we hold about them

The purposes of the processing

The categories of personal data concerned

The recipients to whom the personal data has/will be disclosed

How long we intend to store your personal data for

If we did not collect the data directly from them, information about the source

The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this

The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use

The right to lodge a complaint or seek judicial remedy and who to contact in such instances

Information Security & Technical and Organisational Measures  takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and

precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect 

personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including:

SSL, access controls, password policy, encryptions, pseudonymisation, practices, restriction, IT, authentication.

GDPR Roles and Employees  have designated Gordon Stark as our Appointed Person and have appointed a data privacy team to develop and implement our 

roadmap for complying with the new data protection Regulation. The team are responsible for promoting awareness of the GDPR across the

organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.  understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR. We have

implemented an employee training program specific to GDPR which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.

If you have any questions about our preparation for the GDPR, please contact  Gordon Stark