Policies

It is the Policy of the Company to ensure that our business is conducted according to ethical, professional and legal standards in a fair, honest and open manner.

The Company has a zero-tolerance approach to all forms of bribery and corruption which include:

• The direct or indirect promise, offering or authorisation of anything of value;
• The offer or receipt of any kickback, loan, fee, reward or other advantage;
• The giving of aid, donations or voting designed to exert improper influence;
• Payments for lavish or inappropriate entertainment or travel;
• Favours including offers of employment;
• Facilitation payments;
• Inflated commissions;
• Fake consultancy agreements.

The Company opposes all forms of bribery and corruption, large as well as small, whether initiated by corrupt officials or corrupt companies or individuals, and whether it takes place in the public or private sector, in the UK or abroad.

To adhere to the policy, we will:

• Ensure all Company personnel are provided with training on the Company Policy on anti-bribery and corruption so they can recognise the signs and take steps to avoid it;
• Encourage employees, subcontractors and business partners to report any suspicions of bribery and/or corruption through formal ‘whistle blowing’ channels or more informally through our Company ‘open door’ policy which enables any individuals to discuss any concerns they may have with senior management in a confidential environment;
• Have an understanding of how bribery may occur during the Company’s operations and the impacts this could have, implementing appropriate control measures as necessary to prevent occurrence;
• Use appropriate disciplinary and other sanctions for violations of the policy and/or laws against bribery and corruption.

Failure to comply with this policy may result in disciplinary action, including dismissal or appropriate sanctions, in addition to civil and criminal charges.

Constantly monitor and regularly review this Anti-Bribery and Corruption Policy in order to ensure its continuing suitability.

Undertake monitoring of employee expenses records to ascertain any anomalies which may fall into the scope of this Policy.

Provide copies of this Anti-Bribery and Corruption Policy Statement to all employees.

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This statement is made pursuant to Bribery Act 2010 and forms our statement for the present financial year.

The company has a zero-tolerance approach to slavery and is committed to preventing acts of slavery and human trafficking from occurring within both its business and supply chain. It is expected that all suppliers, contractors and other business partners will uphold these same high standards.

We have ensured due diligence in our processes, by:

• Making our employees aware of the Modern Slavery Act, including the definitions of slavery and human trafficking;
• Telling staff what to do if they suspect a case of slavery or human trafficking;
• Reviewing our Whistleblowing Policy.

These procedures are designed to:

• Identify and assess potential risk areas in our business and supply chains;
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains;
• Monitor potential risk areas in our business and supply chains;
• Provide adequate protection for whistle blowers.

We have a zero tolerance to slavery and human trafficking and require all those in our supply chain and contractors to comply with our values and adopt the same zero tolerance approach. This is communicated to them at the outset of our business relationship and is regularly reinforced thereafter. We may cease to work with individuals and organisations working on our behalf if they do not comply with our approach.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the company’s slavery and human trafficking statement for the present financial year.

The Company acknowledges its activities have an impact on the environment in a number of ways.

The Company therefore aims to adopt sound principles and best practice according to the principles of sustainable development (development that meets the needs of the present without compromising the ability of future generations to meet their own needs) and commits to:

• Integrate environmental management into each aspect of our day-to-day business operation to ensure environmental issues are addressed.
• Comply with environmental legislation and best practice.
• Seek to reduce wastage of resources such as energy, water and raw materials, and maximise the efficient use of such resources, reuse and recycle rather than dispose of such materials.
• Ensure all employees have an understanding and are trained in their responsibilities in relation to the environmental policy and procedures.
• Monitor Company activities on a regular basis to identify strengths and areas for improvement where actions may be required.
• Review Company environmental impacts on a regular basis.

In order to meet the Company commitment to minimising environmental impacts, the Company will:

• Ensure all employees are trained and competent in the tasks they undertake on behalf of the company and training records are held; training will be provided initially during induction and as required thereafter. Further training will be required should the scope of works undertaken by the Company change and/or following monitoring of the Environmental Procedures for continual improvement
• Ensure all employees understand the requirements of this Environmental Policy and abide with the requirements of the Company Environmental Procedures
• Constantly monitor its environmental performance, including during site visits, and implement improvements when appropriate.
• Ensure that all subcontractors / suppliers working on our behalf hold appropriate environmental permits / licenses (e.g. asbestos removal, waste carrier, etc).
• Ensure that timber / timber products are supplied with CPET Category A / B evidence as appropriate.
• Regularly review this Environmental Policy in order to ensure its continuing suitability.
• Provide information to individuals regarding monitoring of the Company Environmental Procedures.
• Provide copies of this Environmental Policy Statement to all employees.

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In House Training & Consultancy Ltd (IHTC Ltd) is fully committed to meeting its responsibilities under the Health & Safety at Work etc, Act 1974, the Management of Health and Safety at Work Regulations 1999 (as amended), and associated protective legislation, both as an employer and as a company. To achieve these objectives the management of IHTC Ltd are responsible for:

• Keeping workplace health, safety and welfare procedures under constant review
• Liaising with the Health and Safety Executive wherever necessary
• Keeping itself abreast of new legislation, EU Directives, Regulations and British Standards, in order to ensure ongoing compliance with the law.

The main responsibility for health and safety lies with the Managing Director, Neill Files. IHTC Ltd is bound by any acts/or omissions of the Managing Director, giving rise to legal liability, provided only that such acts and/or omissions arise out of and in the course of company business.

To comply with its statutory and common law duties, IHTC Ltd has arranged insurance against liability for death, injury and/or disease suffered by any of its employees arising out of and in the course of employment, if caused by negligence and/or breach of statutory duty on the part of IHTC Ltd.

IHTC Ltd employees agree, as part of their contract of employment, to comply with individual duties under both the Health & Safety at Work etc, Act 1974 and the Management of Health and Safety at Work Regulations 1999 (as amended) and will cooperate with IHTC Ltd to enable it to carry out it’s health and safety duties under the Act. Failure to comply with health and safety duties, regulations, work rules and procedures regarding health and safety, on the part of the employee, may lead to dismissal in the case of serious breaches or reputed breaches; such dismissal may be instant and without prior warning.

In accordance with the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013, IHTC Ltd has instituted a system of reporting accidents, diseases and dangerous occurrences to the Health and Safety Executive, in addition to its statutory duty to provide an accident book. IHTC Ltd will comply with its duties towards employees under the Health & Safety at Work etc, Act 1974, the Management of Health and Safety at Work Regulations 1999 (as amended), so far as is reasonably practicable, in order to:

• Provide and maintain plant and systems of work that are safe and without risks to health, a safe place of work, a safe system of work
• Ensure the safety and absence of risks to health in connection with the use, handling, storage and transport of articles and substances
• Provide such information, instruction, training and supervision as may be necessary to ensure the health and safety at work of its employees
• Make regular risk assessments available to employees
• Take appropriate preventative/protective measures
• Provide employees with health surveillance where necessary
• Appoint competent personnel to secure compliance with statutory duties and to undertake reviews of the policy as necessary

In order to meet its obligations towards the general public and all lawful visitors to IHTC Ltd premises, the company will pay strict attention to its duties under the Health and Safety at Work Act and the Occupiers’ Liability Acts 1957 and 1984.

This policy has been prepared in compliance with Section 2(3) of the Health and Safety at Work etc, Act 1974 and binds all Managers and Employees, in the interests of Employees and Customers. We request that our Customers and Visitors respect this Policy, a copy of which can be obtained on demand.

1. Interpretation

1.1 Definitions:

Automated Decision-Making (ADM): when a decision is made which is based solely on Automated Processing (including profiling) which produces legal effects or significantly affects an individual. The GDPR prohibits Automated Decision-Making (unless certain conditions are met) but not Automated Processing.

Automated Processing: any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.

Company Personnel: all employees, workers contractors, agency workers, consultants, directors, members and others.

Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear positive action, signifies agreement to the Processing of Personal Data relating to them.

Data Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Data Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.

Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.

Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programs involving the Processing of Personal Data.

Data Protection Officer (DPO): the person required to be appointed in specific circumstances under the GDPR. Where a mandatory DPO has not been appointed, this term means a data protection manager or other voluntary appointment of a DPO or refers to the Company data privacy team with responsibility for data protection compliance.

EEA: the 28 countries in the EU, and Iceland, Liechtenstein and Norway.

Explicit Consent: consent which requires a very clear and specific statement (that is, not just action).

General Data Protection Regulation (GDPR): the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the GDPR.

Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Sensitive Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour.

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Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.

Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the GDPR.

Privacy Guidelines: the Company privacy/GDPR related guidelines provided to assist in interpreting and implementing this Privacy Policy and Related Policies.

Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies: separate notices setting out information that may be provided to Data Subjects when the Company collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, employee privacy notices or the website privacy policy) or they may be stand-alone, one-time privacy statements covering Processing related to a specific purpose.

Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.

Related Policies: the Company’s policies, operating procedures or processes related to this Privacy Policy and designed to protect Personal Data.

Sensitive Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal Data relating to criminal offences and convictions.

2. Introduction

This Privacy Policy sets out how In House Training & Consultancy Ltd (“we”, “our”, “us”, “the Company”) handle the Personal Data of our customers, suppliers, employees, workers and other third parties.

This Privacy Policy applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject.

This Privacy Policy applies to all Company Personnel (“you”, “your”). You must read, understand and comply with this Privacy Policy when Processing Personal Data on our behalf and attend training on its requirements. This Privacy Policy sets out what we expect from you in order for the Company to comply with applicable law. Your compliance with this Privacy Policy is mandatory. Related Policies and Privacy Guidelines are available to help you interpret and act in accordance with this Privacy Policy. You must also comply with all such Related Policies and Privacy Guidelines. Any breach of this Privacy Policy may result in disciplinary action.

This Privacy Policy (together with Related Policies and Privacy Guidelines) is an internal document and cannot be shared with third parties, clients or regulators without prior authorisation from the DPO.

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3. Scope

We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times. The Company is exposed to potential fines of up to EUR20 million (approximately £18 million) or 4% of total worldwide annual turnover, whichever is higher and depending on the breach, for failure to comply with the provisions of the GDPR.

All staff are responsible for ensuring all Company Personnel comply with this Privacy Policy and need to implement appropriate practices, processes, controls and training to ensure such compliance.

The DPO is responsible for overseeing this Privacy Policy and, as applicable, developing Related Policies and Privacy Guidelines. That post is held by IHTC’s MD.

Please contact the DPO with any questions about the operation of this Privacy Policy or the GDPR or if you have any concerns that this Privacy Policy is not being or has not been followed. In particular, you must always contact the DPO in the following circumstances:

a) if you are unsure of the lawful basis which you are relying on to process Personal Data (including the legitimate interests used by the Company) (see section [5.1] below);

b) if you need to rely on Consent and/or need to capture Explicit Consent (see section [5.2] below);

c) if you need to draft Privacy Notices or Fair Processing Notices (see section [5.3] below);

d) if you are unsure about the retention period for the Personal Data being Processed (see section [9] below);

e) if you are unsure about what security or other measures you need to implement to protect Personal Data (see section [10.1] below);

f) if there has been a Personal Data Breach (section [10.2] below);

g) if you are unsure on what basis to transfer Personal Data outside the EEA (see section [11] below);

h) if you need any assistance dealing with any rights invoked by a Data Subject (see section [12]);

i) whenever you are engaging in a significant new, or change in, Processing activity which is likely to require a DPIA (see section [13.4] below) or plan to use Personal Data for purposes others than what it was collected for;

j) if you plan to undertake any activities involving Automated Processing including profiling or Automated Decision-Making (see section [13.5] below);

k) if you need help complying with applicable law when carrying out direct marketing activities (see section [13.6] below); or

l) if you need help with any contracts or other areas in relation to sharing Personal Data with third parties (including our vendors) (see section [13.7] below).

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4. 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:

a) Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).

b) Collected only for specified, explicit and legitimate purposes (Purpose Limitation).

c) Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).

d) Accurate and where necessary kept up to date (Accuracy).

e) 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).

f) 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).

g) Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).

h) 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).

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

5. Lawfulness, fairness, transparency

5.1 Lawfulness and fairness

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

We will 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:

a) the Data Subject has given his or her Consent;

b) the Processing is necessary for the performance of a contract with the Data Subject;

c) to meet our legal compliance obligations.;

d) to protect the Data Subject’s vital interests;

e) 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.

We will identify and document the legal ground being relied on for each Processing activity [in accordance with the Company’s guidelines on Lawful Basis for Processing Personal Data].

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5.2 Consent

A Data Controller must 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. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters.

Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured. Consent may need to be refreshed if you intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented.

Unless we can rely on another legal basis of Processing, Explicit Consent is usually required for Processing Sensitive Personal Data, for Automated Decision-Making and for cross border data transfers. Usually we will be relying on another legal basis (and not require Explicit Consent) to Process most types of Sensitive Data. Where Explicit Consent is required, you must issue a Fair Processing Notice to the Data Subject to capture Explicit Consent.

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

5.3 Transparency (notifying data subjects)

The GDPR requires Data Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. Such information must be provided through appropriate Privacy Notices or Fair Processing Notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them.

Whenever we collect Personal Data directly from Data Subjects, including for human resources or employment purposes, we must provide the Data Subject with all the information required by the GDPR including the identity of the Data Controller and DPO, how and why we will use, Process, disclose, protect and retain that Personal Data through a Fair Processing Notice which must be presented when the Data Subject first provides the Personal Data.

When Personal Data is collected indirectly (for example, from a third party or publically available source), we must provide the Data Subject with all the information required by the GDPR as soon as possible after collecting/receiving the data. We must also check that the Personal Data was collected by the third party in accordance with the GDPR and on a basis which contemplates our proposed Processing of that Personal Data.

6. Purpose limitation

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

We cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless we have informed the Data Subject of the new purposes and they have consented where necessary.

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7. Data minimisation

Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

We may only Process Personal Data when performing our job duties requires it. We cannot Process Personal Data for any reason unrelated to our job duties.

We may only collect Personal Data that we require for our job duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes.

We must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company’s data retention guidelines.

8. Accuracy

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

We 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. We must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. We must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

9. Storage limitation

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

We will 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 will 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.

We will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice or Fair Processing Notice.

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10. Security integrity and confidentiality

10.1 Protecting Personal Data

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

We will 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 are responsible for protecting the Personal Data we hold. We must 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. We must exercise particular care in protecting Sensitive Personal Data from loss and unauthorised access, use or disclosure.

We will follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. We may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.

We will maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

a) Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it.

b) Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed.

c) Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.

d) We will comply with and not attempt to circumvent the administrative, physical and technical safeguards we implement and maintain in accordance with the GDPR and relevant standards to protect Personal Data.

10.2 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.

If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the person or team designated as the key point of contact for Personal Data Breaches You should preserve all evidence relating to the potential Personal Data Breach.

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11. 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 may only transfer Personal Data outside the EEA if one of the following conditions applies:

a) 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;

b) 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;

c) the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or

d) 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 interest.

12. Data Subject’s rights and requests

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

a) withdraw Consent to Processing at any time;

b) receive certain information about the Data Controller’s Processing activities;

c) request access to their Personal Data that we hold;

d) prevent our use of their Personal Data for direct marketing purposes;

e) 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;

f) restrict Processing in specific circumstances;

g) challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;

h) request a copy of an agreement under which Personal Data is transferred outside of the EEA;

i) object to decisions based solely on Automated Processing, including profiling (ADM);

j) prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;

k) be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;

l) make a complaint to the supervisory authority; and

m) 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 format.

n) We will verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade you into disclosing Personal Data without proper authorisation).

We will immediately forward any Data Subject request wereceive to the DPO.

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13. Accountability

13.1

The Data Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Data Controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.

The Company must have adequate resources and controls in place to ensure and to document GDPR compliance including:

a) appointing a suitably qualified DPO (where necessary) and an executive accountable for data privacy;

b) implementing Privacy by Design when Processing Personal Data and completing DPIAs where Processing presents a high risk to rights and freedoms of Data Subjects;

c) integrating data protection into internal documents including this Privacy Policy, Related Policies, Privacy Guidelines, Privacy Notices or Fair Processing Notices;

d) regularly training Company Personnel on the GDPR, this Privacy Policy, Related Policies and Privacy Guidelines and data protection matters including, for example, Data Subject’s rights, Consent, legal basis, DPIA and Personal Data Breaches. The Company must maintain a record of training attendance by Company Personnel; and

e) regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort.

13.2 Record keeping

The GDPR requires us to keep full and accurate records of all our data Processing activities.

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

These records should include, at a minimum, the name and contact details of the Data Controller and the DPO, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data’s retention period and a description of the security measures in place. In order to create such records, data maps should be created which should include the detail set out above together with appropriate data flows.

13.3 Training and audit

We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.

We will undergo all mandatory data privacy related training and ensure our team undergo similar mandatory training.

We will regularly review all the systems and processes under our control to ensure they comply with this Privacy Policy and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.

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13.4 Privacy by Design and Data Protection Impact Assessment (DPIA)

We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles.

We will assess what Privacy by Design measures can be implemented on all programs/systems/processes that Process Personal Data by taking into account the following:

a) the state of the art;

b) the cost of implementation;

c) the nature, scope, context and purposes of Processing; and

d) the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing.

Data controllers must also conduct DPIAs in respect to high risk Processing.

We should conduct a DPIA (and discuss your findings with the DPO) when implementing major system or business change programs involving the Processing of Personal Data including:

a) use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes);

b) Automated Processing including profiling and ADM;

c) large scale Processing of Sensitive Data; and

d) large scale, systematic monitoring of a publicly accessible area.

A DPIA must include:

a) a description of the Processing, its purposes and the Data Controller’s legitimate interests if appropriate;

b) an assessment of the necessity and proportionality of the Processing in relation to its purpose;

c) an assessment of the risk to individuals; and

d) the risk mitigation measures in place and demonstration of compliance.

13.5 Automated Processing (including profiling) and Automated Decision- Making

Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:

a) a Data Subject has Explicitly Consented;

b) the Processing is authorised by law; or

c) the Processing is necessary for the performance of or entering into a contract.

If certain types of Sensitive Data are being processed, then grounds (b) or (c) will not be allowed but such Sensitive Data can be Processed where it is necessary (unless less intrusive means can be used) for substantial public interest like fraud prevention.

If a decision is to be based solely on Automated Processing (including profiling), then Data Subjects must be informed when we first communicate with them of their right to object. This right must be explicitly brought to their attention and presented clearly and separately from other information. Further, suitable measures must be put in place to safeguard the Data Subject’s rights and freedoms and legitimate interests.

We must also inform the Data Subject of the logic involved in the decision making or profiling, the significance and envisaged consequences and give the Data Subject the right to request human intervention, express their point of view or challenge the decision.

A DPIA must be carried out before any Automated Processing (including profiling) or ADM activities are undertaken.

[Where we are involved in any data Processing activity that involves profiling or ADM, we will comply with the Company’s guidelines on profiling or ADM.]

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13.6 Direct Marketing

We are subject to certain rules and privacy laws when marketing to our customers.

For example, a Data Subject’s prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as “soft opt in” allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.

The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information.

A Data Subject’s objection to direct marketing must be promptly honoured. If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.

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

a) they have a need to know the information for the purposes of providing the contracted services;

b) 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;

c) the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;

d) the transfer complies with any applicable cross border transfer restrictions; and

e) a fully executed written contract that contains GDPR approved third party clauses has been obtained.

14. Review and Amendments to this Privacy Policy

We reserve the right to change this Privacy Policy at any time without notice so please check back regularly to obtain the latest copy of this Privacy Policy.

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