Data Protection Policy

Diversejobsmatter Limited

Data Protection Policy

10 May 2021



1.        Introduction


This Policy sets out the obligations of Diversejobsmatter Limited a company registered in England under company number 12985126 whose registered office is at 2 Devonshire Square, London, EC2M 4UJ (“the Company”) regarding data protection and the rights of job seekers who are looking for a new work related opportunities (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).


The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “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.


This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.


The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.


2.        The Data Protection Principles


This Policy aims to ensure compliance with the GDPR.  The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:


2.1 Processed lawfully, fairly, and in a transparent manner in relation to the data subject.


2.2 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 not be considered to be incompatible with the initial purposes.


2.3 Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.


2.4 Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.


2.5 Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is 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, subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.



2.6 Processed in a manner that ensures appropriate security of the personal data, 

including protectionagainstunauthorised orunlawfulprocessing  andagainst accidentalloss,destruction,ordamage,usingappropriatetechnical or organisationalmeasures.


3.    The Rights of Data Subjects


The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):


3.1The right to beinformed(Part12).


3.2The rightofaccess(Part13);


3.3The right torectification(Part14);


3.4The right to erasure(also known asthe‘right to beforgotten’)(Part15);


3.5The right to data portability(Part16);


3.6The right to object (Part17);and


3.7Rights withrespect to automateddecision-making and profiling(Parts 18 and19).


4. Lawful, Fair, and Transparent Data Processing


4.1TheGDPR seeksto ensurethatpersonal dataisprocessedlawfully,fairly,and transparently,without adverselyaffecting the rights  of  the data subject. The GDPR statesthat processingofpersonal data shallbelawfulif atleast one ofthe following applies:


4.1.1 The data subject has given consent to the processing of their personal data for one or more specific purposes;


4.1.2 The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;


4.1.3 The processing is necessary for compliance with a legal obligation to which the data controller is subject;


4.1.4 The processing is necessary to protect the vital interests of the data subject or of another natural person;


4.1.5Theprocessingisnecessaryfortheperformanceofataskcarriedout inthepublicinterestorintheexerciseofofficial authority vestedinthe datacontroller;or


4.1.6 The processing is necessary for the purposes of the legitimate interests 

pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

4.2 If  the  personal  data  in  question  is  “special  category  data”  (also  known  as “sensitive personal data”) (for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation),  at  least one of the following conditions must be met:


4.2.1Thedatasubjecthas giventheir explicitconsenttotheprocessing of suchdatafor one or morespecifiedpurposes(unlessEU orEU MemberStatelaw prohibitsthemfromdoing so);


4.2.2 The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for  appropriate  safeguards  for the  fundamental rights  and interests of the data subject);


4.2.3 The 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;


4.2.4 The data controller  is a foundation, association,  or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection  with  its  purposes  and  that  the  personal  data  is  not disclosed outside the body without the consent of the data subjects;


4.2.5 The processing relates to personal data which is clearly made public by the data subject;


4.2.6 The  processing  is  necessary  for  the  conduct  of  legal  claims  or whenever courts are acting in their judicial capacity;


4.2.7Theprocessingisnecessaryfor substantial publicinterestreasons,on thebasisofEUorEUMemberStatelawwhichshallbeproportionate tothe aimpursued,shall respectthe essence oftherightto data protection,  and shallprovide for  suitable  and specific measures to safeguardthefundamentalrights andinterests of the data subject;


4.2.8 The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;


4.2.9 The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or


4.2.10The processingis necessary for archiving purposesin the public interest,  scientific  or  historical   research   purposes,   or  statistical purposesinaccordancewithArticle89(1)oftheGDPR based on EU or EUMemberStatelawwhichshall beproportionatetotheaimpursued, respecttheessence oftherightto data protection, and providefor suitableandspecificmeasurestosafeguardthefundamentalrights andtheinterests of thedatasubject.


5. Specified, Explicit, and Legitimate Purposes


5.1    TheCompanycollectsandprocessesthepersonaldatasetoutinPart20ofthis 

         Policy. This includes:


5.1.1Personaldata collected directlyfromdatasubjects.


5.1.2Personaldata obtainedfromthird parties.


5.2 The Company only collects, processes, and holds personal data for the specific purposes set out in Part 20 of this Policy (or for other purposes expressly permitted by the GDPR).


5.3 Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 12 for more information on keeping data subjects informed.


6. Adequate, Relevant, and Limited Data Processing


The  Company will only collect  and process personal data  for and  to  the  extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 5, above, and as set out in Part 20, below.


7. Accuracy of Data and Keeping Data Up-to-Date


7.1 The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part

14, below.


7.2 The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out- of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.


8. Data Retention


8.1 The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.


8.2 When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.


8.3 For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.


9. Secure Processing


The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 21 to 26 of this Policy.


10. Accountability and Record-Keeping


10.1 The Company’s Data Protection Officer is Sebastian Pampanini.


10.2 The   Data   Protection   Officer   shall   be   responsible   for   overseeing   the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the GDPR and other applicable data protection legislation.


10.3 The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:


10.3.1 The name and details of the Company, its Data Protection Officer, and 

any applicable third-party data processors;



10.3.2 The purposes for which the Company collects, holds, and processes 

personal data;


10.3.3 Details of the  categories  of  personal  data  collected,  held,  and 

        processed by the Company, and the categories of data subject to which 

        that personal data relates;


10.3.4 Details of any  transfers  of  personal  data  to  non-EEA  countries 

including all mechanisms and security safeguards;


10.3.5 Details of how long personal data will be retained by the Company

(please refer to the Company’s Data Retention Policy); and


10.3.6 Detailed descriptions of  all  technical  and  organisational  measures 

taken by the Company to ensure the security of personal data.


11. Data Protection Impact Assessments


11.1 The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data.


11.2 Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:


11.2.1 Thetype(s)ofpersonal datathatwillbe collected,held,and processed;


11.2.2The purpose(s) for which personaldataisto be used;


11.2.3The Company’s objectives;


11.2.4Howpersonaldataisto be used;


11.2.5The parties (internaland/orexternal)who areto beconsulted;


11.2.6 The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;


11.2.7Risks posedtodatasubjects;


11.2.8Risks posedbothwithin andtothe Company;and


11.2.9Proposedmeasurestominimise andhandleidentified risks.


12. Keeping Data Subjects Informed


12.1TheCompanyshallprovidetheinformationsetoutinPart12.2toeverydata subject:


12.1.1Wherepersonaldataiscollecteddirectlyfromdatasubjects,those data subjectswill beinformed ofitspurpose atthetime ofcollection; and


12.1.2Wherepersonal dataisobtainedfromathirdparty,therelevantdata  subjectswillbeinformed ofits purpose:


a)ifthepersonaldataisusedtocommunicatewith thedatasubject, whenthefirstcommunicationismade;or


b)ifthepersonaldataistobetransferredtoanotherparty,beforethat transferismade;or


c)assoonasreasonablypossibleandinanyeventnotmorethanone month after thepersonaldatais obtained.



12.2 The following information shall be provided:


12.2.1DetailsoftheCompanyincluding,butnotlimitedto,theidentityofits Data Protection Officer;


12.2.2Thepurpose(s)forwhichthepersonaldataisbeingcollectedandwill beprocessed(asdetailedinPart20ofthisPolicy) andthelegal basis justifyingthatcollection and processing;


12.2.3Where applicable,thelegitimateinterests uponwhichthe Companyis justifyingits collection and processing of the personaldata;


12.2.4Wherethepersonal dataisnotobtained directly fromthedata subject, 

the categories ofpersonaldata collected and processed;


12.2.5Wherethepersonaldataistobetransferredtooneormorethird parties,details of those parties;


12.2.6Wherethepersonal dataistobetransferredtoathirdpartythatis located outside of the EuropeanEconomic Area(the“EEA”), details of thattransfer,includingbut notlimitedtothesafeguardsinplace(see Part27 of this Policyfor furtherdetails);


12.2.7Details ofdataretention;


12.2.8Details of the data subject’srights under the GDPR;


12.2.9Detailsofthedatasubject’srighttowithdrawtheirconsenttothe Company’s processing of theirpersonaldata atany time;


12.2.10Details of the data subject’s right to complain to the Information 

Commissioner’s Office(the“supervisoryauthority”under the GDPR);


12.2.11Where applicable,detailsofanylegal orcontractual requirementor obligationnecessitatingthecollectionandprocessingofthe personal    data and details ofanyconsequences of failingto provideit;and


12.2.12Detailsof any automated decision-making or profilingthat willtake placeusingthepersonal data,includinginformationonhow decisions  will bemade,the significanceof those decisions,and any consequences.


13. Data Subject Access


13.1 Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.


13.2 Employees wishing to make a SAR should do using a Subject Access Request Form, sending the form to the Company’s Data Protection Officer at 2 Devonshire Square, London, EC2M 4UJ.


13.3 Responses to SARs shall normally be made within one month of receipt, however this  may  be  extended  by  up  to  two  months  if  the  SAR  is  complex  and/or numerous requests are made. If such additional time is required, the data subject shall be informed.


13.4 All SARs received shall be handled by the Company’s Data Protection Officer.


13.5 The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.



14. Rectification of Personal Data


14.1 Data subjects have  the  right  to  require  the  Company  to  rectify  any  of  their personal data that is inaccurate or incomplete.


14.2 The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.


14.3 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.


15. Erasure of Personal Data


15.1 Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:


15.1.1ItisnolongernecessaryfortheCompanytoholdthatpersonal data withrespect tothepurpose(s)forwhichitwasoriginally collectedor processed;


15.1.2 The data subject wishes to withdraw their consent to the Company holding and processing their personal data;


15.1.3Thedatasubjectobjectsto the Company holdingandprocessingtheir personaldata(andthereisnooverridinglegitimateinteresttoallow the Company tocontinue doing so)(seePart 17ofthisPolicy forfurther details concerningtheright to object);


15.1.4The personaldata has been processedunlawfully;



15.1.5Thepersonal dataneedstobeerasedinorderfortheCompanyto comply witha particularlegalobligation.


15.2 Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.


15.3 In the event that any personal data that is to be erased in response to a data subject’s  request  has been disclosed  to  third  parties,  those parties  shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).


16. Data Portability


16.1 The Company processes personal data using automated means.


16.2 Where data subjects have given their consent to the Company to process their personal data in such a manner, or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the right, under the GDPR, to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers).


16.3 To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the following format:


16.3.1   MicrosoftExcel;


16.4 Where technically feasible, if requested by a data subject, personal data shall be sent directly to the required data controller.


16.5 All requests for copies of personal data shall be complied with within one month of the data subject’s request. The period can be extended by up to two months in the case of complex or numerous requests. If such additional time is required, the data subject shall be informed.


17. Objections to Personal Data Processing


17.1Datasubjectshavetherighttoobjectto theCompany processingtheir personal Data basedon legitimate interests,  direct  marketing (including  profiling),  and processingforscientific and/orhistoricalresearchandstatistics purposes.


17.2 Where a data subject objects to the Company processing their personal data based on its  legitimate  interests, the Company shall cease  such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.


17.3 Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.


18. Automated Decision-Making


18.1 The Company uses personal data in automated decision-making processes using targeted Diversejobsmatter Database searches.


18.2 Where  such  decisions  have  a  legal  (or  similarly  significant  effect)  on  data subjects, those data subjects have the right to challenge to such decisions under the GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.


18.3 The right described in Part 18.2 does not apply in the following circumstances:


18.3.1Thedecisionisnecessaryfortheentryinto,orperformanceof,a contractbetweentheCompanyandthedata subject;


18.3.2The decisionis authorised bylaw; or


18.3.3The datasubjecthasgiventheirexplicitconsent.


19. Profiling


19.1TheCompany usespersonal datafor profilingpurposes.Matching job seekers with live roles.


19.2Whenpersonaldatais usedforprofiling purposes, thefollowing shallapply:


19.2.1Clear information explaining the profiling shallbe provided  to data 

subjects, including the significanceandlikelyconsequences  of the 



19.2.2Appropriate mathematical or statistical procedures shall be used;


19.2.3Technical  and organisational  measures shall be implemented to minimisetheriskof errors.If errorsoccur, such measuresmustenable themto beeasilycorrected;and


19.2.4All personal data processedforprofilingpurposesshall besecuredin ordertopreventdiscriminatoryeffectsarisingout of profiling(seeParts 21to 25 of this Policy formoredetails on datasecurity).







20. Personal Data Collected, Held, and Processed


Thefollowingpersonaldataiscollected,held,andprocessedbytheCompany(for details ofdataretention,pleaserefer tothe Company’s Data Retention Policy):



Data Ref.

Type of Data

Purpose of Data




Date of birth










Email address


Find Suitable jobs

Telephone number


Find Suitable jobs



Data Ref.

Type of Data

Purpose of Data

Job title


Find Suitable jobs



Find Suitable jobs

Payment Information


Making Payments

Info about your preferences and interest




Find Suitable jobs



21. Data Security - Transferring Personal Data and Communications


The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:


21.1 All emails containing personal data must be encrypted  using 164K BIT data encryption. All emails containing personal data must be marked “confidential”;


21.2 Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;


21.3 Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;


21.4 Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted.  All temporary files  associated  therewith  should  also  be deleted using the delete key;


21.5 Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;


21.6 Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient;


21.7 All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.



22. Data Security - Storage


The Company shall ensure that the following measures are taken with respect to the storage of personal data:


22.1 All electronic copies of personal data should be stored securely using passwords and using 164K BIT data encryption.


22.2 All  hardcopies  of  personal data,  along  with  any electronic  copies  stored  on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;


22.3 All personal data stored electronically should be  backed  up  twice  daily  with backups stored onsite AND/OR offsite. All backups should be encrypted using164K BIT data encryption


22.4 No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of Sebastian Pampanini, Operations Director, 07805 547592 and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and


22.5Nopersonal datashouldbetransferredtoany devicepersonally belongingtoan employeeandpersonal datamay onlybetransferredtodevicesbelongingto agents, contractors,or otherpartiesworkingonbehalf oftheCompanywherethe partyinquestionhas agreedtocomplyfully withtheletter and spirit ofthisPolicy and ofthe GDPR(whichmayinclude demonstratingtotheCompanythat all suitabletechnicaland organisationalmeasures havebeentaken).


23. Data Security - Disposal


When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.


24. Data Security - Use of Personal Data


The Company shall ensure that the following measures are taken with respect to the use of personal data:


24.1 No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from Sebastian Pampanini, Operations Director, 07805 547592;


24.2 No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of Sebastian Pampanini, Operations Director, 07805 547592;


24.3 Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;


24.4 If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and




547592 to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.


25. Data Security - IT Security



andinformation security:


25.1 All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. All software used by the Company is designed to require such passwords;


25.2Under  no  circumstances should any passwords be written down  or shared betweenanyemployees,agents,contractors,orotherpartiesworkingonbehalf of  the  Company, irrespective  of  seniority  or  department.  If  a  password is forgotten,itmust beresetusingtheapplicablemethod.IT staff do not have accessto passwords;


25.3 All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates as soon as reasonably and practically possible, unless there are valid technical reasons not to do so;


25.4 No  software  may  be  installed  on  any  Company-owned  computer  or  device without  the  prior  approval  of  the  Sebastian  Pampanini,  Operations  Director, 07805 547592.


26. Organisational Measures


The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:


26.1Allemployees,agents,contractors,orotherpartiesworkingonbehalfofthe Companyshallbemadefullyawareofboththeirindividualresponsibilitiesand theCompany’sresponsibilitiesunderthe GDPRandunderthisPolicy, andshall be provided witha copyof this Policy;


26.2Onlyemployees,agents,sub-contractors,orotherpartiesworkingonbehalfof theCompanythat need accessto, anduse of,personal datainordertocarry out theirassigned dutiescorrectly shall haveaccessto personal dataheldbythe Company;


26.3 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;


26.4 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;


26.5 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;


26.6Methods ofcollecting,holding,andprocessing personal data shall beregularly evaluatedandreviewed;


26.7 All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;


26.8 The  performance  of  those  employees,  agents,  contractors,  or  other  parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;


26.9 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;


26.10 All  agents,  contractors,  or  other  parties  working  on  behalf  of  the  Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the GDPR; and


26.11Where any agent, contractor or other partyworking on behalf ofthe Company handlingpersonal datafailsintheirobligationsunderthisPolicythatparty shall indemnify andholdharmlesstheCompany against anycosts,liability,damages, loss,claims orproceedingswhichmayarise outof that failure.


27. Transferring Personal Data to a Country Outside the EEA


27.1 The Company may from time to time transfer (‘transfer’ includes making  available remotely) personal data to countries outside of the EEA.


27.2 The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:


27.2.1Thetransferistoacountry,territory,or oneor more specificsectorsin thatcountry(oraninternational organisation),thattheEuropean Commissionhasdeterminedensuresanadequatelevelofprotection forpersonaldata;


27.2.2The transfer is to a country (or international  organisation) which provides appropriatesafeguardsintheformof alegally binding agreement betweenpublic authorities or bodies; binding corporate rules; standard dataprotectionclausesadoptedbytheEuropean Commission;compliancewithan approved code ofconduct approved by asupervisory authority (e.g.theInformation Commissioner’sOffice); certificationunderanapprovedcertificationmechanism(asprovided forintheGDPR);contractual clausesagreed andauthorisedbythe competentsupervisory authority; orprovisionsinsertedinto administrativearrangementsbetween publicauthoritiesor bodies authorised by thecompetent supervisoryauthority;


27.2.3Thetransferismadewiththeinformed consentoftherelevant data subject(s);


27.2.4 The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);


27.2.5Thetransferis necessary forimportantpublicinterest reasons;


27.2.6Thetransferis necessary for the conductoflegalclaims;


27.2.7The transfer  is  necessary to  protect  thevital  interests  of  thedata subjectorotherindividualswherethedatasubjectis  physicallyor legallyunabletogivetheirconsent;or


27.2.8Thetransferismadefromaregisterthat,underUKorEUlaw,is intended to provide information to thepublic and whichis open for accessbythepublicingeneral orotherwisetothosewhoareableto showalegitimateinterestin accessingtheregister.



28. Data Breach Notification


28.1All personal databreaches mustbereportedimmediatelytotheCompany’s \ Data Protection Officer.


28.2 If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.


28.3 In the event that a personal data breach is likely to result in a high risk (that is,  a higher risk than that described under Part 28.2) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.


28.4    Data breach notifications shall include the following information:


28.4.1The categories andapproximatenumberofdata subjects concerned;


28.4.2The categories and approximate number of personal  data records 




  (orothercontactpoint wheremoreinformation can beobtained);


28.4.4Thelikely consequences of the breach;


28.4.5Details of the measures taken,  or proposed to  be taken, by the Company toaddressthebreachincluding,whereappropriate, measurestomitigateits possible adverseeffects.


29. Implementation of Policy


ThisPolicyshall bedeemedeffective as of07 May2021.No part ofthisPolicyshall haveretroactive effectand shall thusapply onlytomatters occurringon orafterthis date.



This Policy has been approved and authorised by:


Name:                              Sebastian Pampanini Position:                         Operations Director Date:                                10 May 2021

Due for Review by:        10 May 2022