ANNEX 2 – Privacy Policy

1. Personal data protection principles

We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:

  1. Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
  2. Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
  3. Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).
  4. Accurate and where necessary kept up to date (Accuracy).
  5. Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).
  6. Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).
  7. Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
  8. Made available to Data Subjects and Data Subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject's Rights and Requests).

We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).

1.2 Lawfulness and fairness

Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject.

We only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing, but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.

The GDPR allows Processing for specific purposes, some of which are set out below:

  1. the Data Subject has given his or her Consent;
  2. the Processing is necessary for the performance of a contract with the Data Subject;
  3. to meet our legal compliance ;
  4. to protect the Data Subject's vital interests;
  5. to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices or Fair Processing Notices; or

We identify and document the legal ground being relied on for each Processing activity.

1.3 Consent

We only process Personal Data on the basis of one or more of the lawful bases set out in the GDPR, which include Consent.

A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing.

You keep evidence Consent captured and keep records of all Consents so that the Company can demonstrate compliance with Consent requirements.

2. Purpose limitation

Personal Data is only collected for specified, explicit and legitimate purposes. It is not further Processed in any manner incompatible with those purposes.

3. Accuracy

Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.

You will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

4. Storage limitation

Personal Data must is not kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.

We do not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.

The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires such data to be kept for a minimum time.

We take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all the Company's applicable records retention schedules and policies. This includes requiring third parties to delete such data where applicable.

4.1 Protecting Personal Data

Personal Data is secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

We develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. We implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data. 

4.2 Reporting a Personal Data Breach

The GDPR requires Data Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data Subject.

We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.

5. Transfer limitation

The GDPR restricts data transfers to countries outside the EEA in order to ensure that the level of data protection afforded to individuals by the GDPR is not undermined. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country.

We only transfer Personal Data outside the EEA if one of the following conditions applies:

  1. the European Commission has issued a decision confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subjects' rights and freedoms;
  2. appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by the European Commission, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the DPO (where applicable);
  3. the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or
  4. the transfer is necessary for one of the other reasons set out in the GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate

6. Data Subject's rights and requests

Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:

  1. withdraw Consent to Processing at any time;
  2. receive certain information about the Data Controller's Processing activities;
  3. request access to their Personal Data that we hold;
  4. prevent our use of their Personal Data for direct marketing purposes;
  5. ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;
  6. restrict Processing in specific circumstances;
  7. challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;
  8. request a copy of an agreement under which Personal Data is transferred outside of the EEA;
  9. object to decisions based solely on Automated Processing, including profiling (ADM);
  10. prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;
  11. be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;
  12. make a complaint to the supervisory authority; and
  13. in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine readable

7. Record keeping

We keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects' Consents and procedures for obtaining Consents.

7.1 Sharing Personal Data

Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.

We only share the Personal Data we hold with another employee, agent or representative of our group (which includes our subsidiaries and our ultimate holding company along with its subsidiaries) if the recipient has a job-related need to know the information and the  transfer complies with any applicable cross-border transfer restrictions.

We only share the Personal Data we hold with third parties, such as our service providers if:

  1. they have a need to know the information for the purposes of providing the contracted services;
  2. sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject's Consent has been obtained;
  3. the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
  4. the transfer complies with any applicable cross border transfer restrictions; and
  5. a fully executed written contract that contains GDPR approved third party clauses has been

This Privacy Standard does not override any applicable national data privacy laws and regulations in countries where the Company operates.