Data Protection Policy

Introduction

This Policy sets out the obligations of DYC Electrical Services Limited, a company registered in England under number 09953900, whose registered office is at County House, Saint Mary’s Street, Worcester (“the Company”) regarding data protection and the rights of clients, employees (“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.

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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 protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

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):

3.1 The right to be informed (Part 12).

3.2 The right of access (Part 13);

3.3 The right to rectification (Part 14);

3.4 The right to erasure (also known as the ‘right to be forgotten’) (Part 15);

3.5 The right to restrict processing (Part 16);

3.6 The right to data portability (Part 17);

3.7 The right to object (Part 18); and

3.8 Rights with respect to automated decision-making and profiling (Parts 19 and 20).

4. Lawful, Fair, and Transparent Data Processing

4.1 The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the 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;

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4.1.5 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

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:

4.2.1 The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing 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;
4.2.7 The processing is necessary for substantial public interest reasons, on
the basis of EU or EU Member State law which shall be proportionate
to the aim pursued, shall respect the essence of the right to data
protection, and shall provide for suitable and specific measures to
safeguard the fundamental rights and interests 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;

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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
4.2.10 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 EU or
EU Member State law which shall 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
5.1 The Company collects and processes the personal data set out in Part 21 of
this Policy. This includes:
5.1.1 Personal data collected directly from data subjects[.] OR [; and]
5.1.2 [Personal data obtained from third parties.]
5.2 The Company only collects, processes, and holds personal data for the
specific purposes set out in Part 21 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 21,
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] OR [<<insert interval>>] 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

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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 22 to 27 of this
Policy.
10. Accountability and Record-Keeping
10.1 The Company’s Data Protection Officer is Dario Careaga.
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 [which involve the use of
new technologies and the processing involved is likely to result in a high risk to
the rights and freedoms of data subjects under the GDPR].
11.2 Data Protection Impact Assessments shall be overseen by the Data Protection
Officer and shall address the following:

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11.2.1 The type(s) of personal data that will be collected, held, and
processed;
11.2.2 The purpose(s) for which personal data is to be used;
11.2.3 The Company’s objectives;
11.2.4 How personal data is to be used;
11.2.5 The parties (internal and/or external) who are to be consulted;
11.2.6 The necessity and proportionality of the data processing with respect to
the purpose(s) for which it is being processed;
11.2.7 Risks posed to data subjects;
11.2.8 Risks posed both within and to the Company; and
11.2.9 Proposed measures to minimise and handle identified risks.

12. Keeping Data Subjects Informed
12.1 The Company shall provide the information set out in Part 12.2 to every data
subject:
12.1.1 Where personal data is collected directly from data subjects, those
data subjects will be informed of its purpose at the time of collection;
and
12.1.2 Where personal data is obtained from a third party, the relevant data
subjects will be informed of its purpose:
a) if the personal data is used to communicate with the data subject,
when the first communication is made; or
b) if the personal data is to be transferred to another party, before that
transfer is made; or
c) as soon as reasonably possible and in any event not more than one
month after the personal data is obtained.
12.2 The following information shall be provided:
12.2.1 Details of the Company including, but not limited to, the identity of its
Data Protection Officer;
12.2.2 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;
12.2.3 Where applicable, the legitimate interests upon which the Company is
justifying its collection and processing of the personal data;
12.2.4 Where the personal data is not obtained directly from the data subject,
the categories of personal data collected and processed;
12.2.5 Where the personal data is to be transferred to one or more third
parties, details of those parties;
12.2.6 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);
12.2.7 Details of data retention;

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12.2.8 Details of the data subject’s rights under the GDPR;
12.2.9 Details of the data subject’s right to withdraw their consent to the
Company’s processing of their personal data at any time;
12.2.10Details of the data subject’s right to complain to the Information
Commissioner’s Office (the “supervisory authority” under the GDPR);
12.2.11Where 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
12.2.12Details 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
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
enquiries@dyc-electrical.co.uk
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:

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15.1.1 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;
15.1.2 The data subject wishes to withdraw their consent to the Company
holding and processing their personal data;
15.1.3 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);
15.1.4 The personal data has been processed unlawfully;
15.1.5 The personal data needs to be erased in order for the Company to
comply with a particular legal obligation[;] OR [.]
15.1.6 [The personal data is being held and processed for the purpose of
providing information society services to a child.]

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. Restriction of Personal Data Processing
16.1 Data subjects may request that the Company ceases processing the personal
data it holds about them. If a data subject makes such a request, the
Company shall retain only the amount of personal data concerning that data
subject (if any) that is necessary to ensure that the personal data in question
is not processed further.
16.2 In the event that any affected personal data has been disclosed to third
parties, those parties shall be informed of the applicable restrictions on
processing it (unless it is impossible or would require disproportionate effort to
do so).
17. [Data Portability
17.1 The Company doesn’t processes personal data using automated means.
18. Objections to Personal Data Processing
18.1 Data subjects have the right to object to the Company processing their
personal data based on legitimate interests, direct marketing (including
profiling), [and processing for scientific and/or historical research and statistics
purposes].
18.2 Where a data subject objects to the Company processing their personal data
based on its legitimate interests, the Company shall cease such processing

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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.
18.3 Where a data subject objects to the Company processing their personal data
for direct marketing purposes, the Company shall cease such processing
immediately.
18.4 Where a data subject objects to the Company processing their personal data
for scientific and/or historical research and statistics purposes, the data
subject must, under the GDPR, “demonstrate grounds relating to his or her
particular situation”. The Company is not required to comply if the research is
necessary for the performance of a task carried out for reasons of public
interest.]

19. [Automated Decision-Making
19.1 The Company uses personal data in automated decision-making processes.
Via Quickbooks
19.2 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.
19.3 The right described in Part 19.2 does not apply in the following circumstances:
19.3.1 The decision is necessary for the entry into, or performance of, a
contract between the Company and the data subject;
19.3.2 The decision is authorised by law; or
19.3.3 The data subject has given their explicit consent.]

20. Profiling
20.1 The Company don’t uses personal data for profiling.
21. Personal Data Collected, Held, and Processed
The following personal data is collected, held, and processed by the Company (for
details of data retention, please refer to the Company’s Data Retention Policy):
Data Ref. Type of Data Purpose of Data
Ref.data.01 Clients Invoicing, quoting, contracts.
Ref.data.02 Employees Works for the company
Ref.data.o3 Supliers Buying, purchasing
22. 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:
22.1 All emails containing personal data must be encrypted
22.2 All emails containing personal data must be marked “confidential”;
22.3 Personal data may be transmitted over secure networks only; transmission

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over unsecured networks is not permitted in any circumstances;
22.4 Personal data may not be transmitted over a wireless network if there is a
wired alternative that is reasonably practicable;
22.5 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
22.6 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;
22.7 Where personal data is to be transferred in hardcopy form it should be passed
directly to the recipient and
22.8 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”.
23. Data Security – Storage
The Company shall ensure that the following measures are taken with respect to the
storage of personal data:
23.1 All electronic copies of personal data should be stored securely using
passwords and Quickbooks data encryption;
23.2 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;
23.3 All personal data stored electronically should be backed up monthly with
backups stored [onsite] AND/OR [offsite]. All backups should be encrypted
23.4 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 Dario
Careaga Managing director of DYC Electrical Services Limited 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
23.5 No personal data should be transferred to any device personally belonging to
an employee and personal data may only be transferred to devices belonging
to agents, contractors, or other parties working on behalf of the Company
where the party in question has agreed to comply fully with the letter and spirit
of this Policy and of the GDPR (which may include demonstrating to the
Company that all suitable technical and organisational measures have been
taken).
24. 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.

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25. Data Security – Use of Personal Data
The Company shall ensure that the following measures are taken with respect to the
use of personal data:

25.1 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 Dario Careaga Managing director of DYC
Electrical Services Limited;
25.2 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 Dario Careaga Managing director of DYC
Electrical Services Limited;
25.3 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;
25.4 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
25.5 Where personal data held by the Company is used for marketing purposes, it
shall be the responsibility of Dario Careaga Managing director of DYC
Electrical Services Limited 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.
26. Data Security – IT Security
The Company shall ensure that the following measures are taken with respect to IT
and information security:
26.1 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.];
26.2 Under no circumstances should any passwords be written down or shared
between any employees, agents, contractors, or other parties working on
behalf of the Company, irrespective of seniority or department. If a password
is forgotten, it must be reset using the applicable method. IT staff do not have
access to passwords;
26.3 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 [not more than 1 month after the
updates are made available by the publisher or manufacturer] OR [as soon as
reasonably and practically possible] [, unless there are valid technical reasons
not to do so]; and
26.4 No software may be installed on any Company-owned computer or device
without the prior approval of the Dario Careaga Managing director of DYC
Electrical Services Limited.

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27. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the
collection, holding, and processing of personal data:
27.1 All employees, agents, contractors, or other parties working on behalf of the
Company shall be made fully aware of both their individual responsibilities and
the Company’s responsibilities under the GDPR and under this Policy, and
shall be provided with a copy of this Policy;
27.2 Only employees, agents, sub-contractors, or other parties working on behalf of
the Company that need access to, and use of, personal data in order to carry
out their assigned duties correctly shall have access to personal data held by
the Company;
27.3 All employees, agents, contractors, or other parties working on behalf of the
Company handling personal data will be appropriately trained to do so;
27.4 All employees, agents, contractors, or other parties working on behalf of the
Company handling personal data will be appropriately supervised;
27.5 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;
27.6 Methods of collecting, holding, and processing personal data shall be regularly
evaluated and reviewed;
27.7 All personal data held by the Company shall be reviewed periodically, as set
out in the Company’s Data Retention Policy;
27.8 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;
27.9 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;
27.10 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
27.11 Where any agent, contractor or other party working on behalf of the Company
handling personal data fails in their obligations under this Policy that party
shall indemnify and hold harmless the Company against any costs, liability,
damages, loss, claims or proceedings which may arise out of that failure.

28. Transferring Personal Data to a Country Outside the EEA
28.1 The Company may from time to time transfer (‘transfer’ includes making
available remotely) personal data to countries outside of the EEA.
28.2 The transfer of personal data to a country outside of the EEA shall take place
only if one or more of the following applies:
28.2.1 The transfer is to a country, territory, or one or more specific sectors in
that country (or an international organisation), that the European

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Commission has determined ensures an adequate level of protection
for personal data;
28.2.2 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;
28.2.3 The transfer is made with the informed consent of the relevant data
subject(s);
28.2.4 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);
28.2.5 The transfer is necessary for important public interest reasons;
28.2.6 The transfer is necessary for the conduct of legal claims;
28.2.7 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
28.2.8 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.

29. Data Breach Notification
29.1 All personal data breaches must be reported immediately to the Company’s
Data Protection Officer.
29.2 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.
29.3 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 29.2) 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.
29.4 Data breach notifications shall include the following information:
29.4.1 The categories and approximate number of data subjects concerned;
29.4.2 The categories and approximate number of personal data records
concerned;
29.4.3 The name and contact details of the Company’s data protection officer
(or other contact point where more information can be obtained);

GDPR Data Protection Policy 14

29.4.4 The likely consequences of the breach;
29.4.5 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.

30. Implementation of Policy
This Policy shall be deemed effective as of 16/08/2018. No part of this Policy shall
have retroactive effect and shall thus apply only to matters occurring on or after this
date.
This Policy has been approved and authorised by:
Name: Dario Careaga
Position: Managing Director
Date: 16/08/2018