Terms of use

1. Our service

2. Ownership of content

3. Use of content

4. Suspension

5. Limitation of liability

6. Indemnity

7. Changes

8. Termination

9. Miscellaneous

11. Contact

Privacy policy

Statement of general policy

Policy aims

• Comply with and/or exceed all relevant regulatory requirements;
• Continually monitor and improve the secure protection of data;
• Incorporate data security factors into business decisions; and
• Increase employee awareness and training.

Policy terms

1.Introduction

2. The data protection principles

3. The rights of data subjects

4. Lawful, fair and transparent data processing

• a) The data subject has given consent to the processing of their personal data for one or more specific purposes;
• b) 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;
• c) The processing is necessary for compliance with a legal obligation to which the data controller is subject;
• d) The processing is necessary to protect the vital interests of the data subject or of another natural person;
• e) The 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 data controller; or
• f) 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.

• a) The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless UK law prohibits them from doing so);
• b) 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 UK law or a collective agreement pursuant to UK law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);
• c) 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;
• d) 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;
• e) The processing relates to personal data which is clearly made public by the data subject;
• f) The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;
• g) The processing is necessary for substantial public interest reasons, on the basis of law which will be proportionate to the aim pursued, will respect the essence of the right to data protection, and will provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;
• h) 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 UK 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;
• i) 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 UK law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or
• j) The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on UK law which will be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

5.Specified, explicit, and legitimate purposes

• a) Personal data collected directly from data subjects and
• b) Personal data obtained from third parties.

6. Adequate, relevant, and limited data processing

7. Accuracy of data and keeping data up-to-date

8.Data retention

9. Secure processing

The Company will 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 will be taken are provided in Parts 22 to 27 of this Policy.

10. Accountability and record-keeping

10.1 The Company’s Data Protection Officer is Andrew Nugée, Chief Executive, or anyone to whom he may from time to time delegate this responsibility. 10.2 The Data Protection Officer will 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 will keep written internal records of all personal data collection, holding, and processing, which will incorporate the following information:

• a) The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;
• b) The purposes for which the Company collects, holds, and processes personal data;
• c) 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;
• d) Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
• e) Details of how long personal data will be retained by the Company; and
• f) Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

11. Data protection impact assessments

• a) The type(s) of personal data that will be collected, held, and processed;
• b) The purpose(s) for which personal data is to be used;
• c) The Company’s objectives;
• d) How personal data is to be used;
• e) The parties (internal and/or external) who are to be consulted;
• f) The necessity and proportionality of the data processing with respect to the purpose(s)for which it is being processed;
• g) Risks posed to data subjects;
• h) Risks posed both within and to the Company; and
• i) Proposed measures to minimise and handle identified risks.

12. Keeping data subjects informed

• a) Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and
• b) Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose if the personal data is used to communicate with the data subject, when the first communication is made; or if the personal data is to be transferred to another party, before that transfer is made; or as soon as reasonably possible and in any event not more than one month after the personal data is obtained.

• a) Details of the Company including, but not limited to, the identity of its Data Protection Officer;
• b) The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;
• c) Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
• d) Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
• e) Where the personal data is to be transferred to one or more third parties, details of those parties;
• f) Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 28 of this Policy for further details);
• g) Details of data retention;
• h) Details of the data subject’s rights under the GDPR;
• i) Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
• j) Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the GDPR);
• k) Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and
• l) Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

13. Data subject access

14. Rectification of personal data

15. Erasure of personal data

• a) It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
• b) The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
• c) The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning the right to object);
• d) The personal data has been processed unlawfully; or
• e) The personal data needs to be erased in order for the Company to comply with a particular legal obligation.

16. Restriction of personal data processing

17. Data portability

18. Objections to personal data processing

19. Profiling

• a) Clear information explaining the profiling will be provided to data subjects, including the significance and likely consequences of the profiling;
• b) Appropriate mathematical or statistical procedures will be used;
• c) Technical and organisational measures will be implemented to minimise the risk of errors. If errors occur, such measures must enable them to be easily corrected; and
• d) All personal data processed for profiling purposes will be secured in order to prevent discriminatory effects arising out of profiling.

20. Personal data collected, held, and processed

21. Data security – transferring personal data and communications

22. Data security – storage

23. Data security – disposal

24. Data security – use of personal data

25. DATA SECURITY – IT SECURITY

26. Organisational measures

27. Transferring personal data to a country outside the EEA

• a) The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
• b) The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
• c) The transfer is made with the informed consent of the relevant data subject(s);
• d) 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);
• e) The transfer is necessary for important public interest reasons;
• f) The transfer is necessary for the conduct of legal claims;
• g) The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
• h) The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

28. Data Breach notification

• a) The categories and approximate number of data subjects concerned;
• b) The categories and approximate number of personal data records concerned;
• c) The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
• d) The likely consequences of the breach;
• e) Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

29. Implementation of policy

30. Contact