We are committed to being transparent about how we collect and use the Personal Data we process and to meeting our data protection obligations. This policy sets out our commitment to data protection, and individual rights and obligations in relation to their Personal Data.

This policy applies to the Personal Data of our employees, clients, suppliers and other third parties.

We have appointed a Compliance Manager who is the person with responsibility for data protection compliance. Questions about this policy, or requests for further information should be directed to them.

Definitions

Criminal Records Data: means information about an Individual’s criminal convictions and offences, and information relating to criminal allegations, criminal offences and related proceedings, including the disposal of such proceedings or the sentence of any court in such proceedings.

Data Controllers’, are the people who or organisations which determine the purposes for which, and the manner in which, any Personal Data is Processed. They are responsible for establishing practices and policies in line with relevant data protection legislation. We are the Data Controller of all Personal Data used in the business for our own commercial purposes and with respect to our employees.¹

Data Processors: include any person or organisation that Processes Personal Data on our behalf, another’s behalf and on our instructions. Employees of Data Controllers are excluded from this definition but it could include suppliers which handle Personal Data on our behalf and it can also apply If we handle Personal Data on behalf of a Data Controller.

Data Protection Breach: means 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 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.

Data Subjects: for the purpose of this policy is an identified or Identifiable natural person, who 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 and who need not be a UK national or resident All Data Subjects have legal rights in relation to their Personal Data.

Personal Data: means Information relating to a Data Subject. Personal Data can be factual (for example, a name, address, e-mail address (Including business), date of birth, health data or employee bank details) ar it can be an opinion about that person, their actions and behaviour. It can be stored electronically or in paper-form. For the purposes of this Policy It also includes Criminal Records Data.

Privacy by Design: means implementing appropriate technical and organisational measures in an effective manner to ensure compliance with data protection legislation.

Processing: is any activity that Involves use of the Personal Data, It includes obtaining, recording or holding the Personal Data, or carrying out any operation or set of operations on the Personal Data Including: accessing, organising, amending, retrieving, using, storing, disclosing, erasing or destroying it. Processing also includes transferring Personal Data to third parties and ‘Process’ and ‘Processed’ shall be construed accordingly,

Special Categories of Personal Data: Includes information about a Data Subjects racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health or condition, sex life or sexual orientation, genetic or biometric data, or about the commission of, or proceedings for, Special Categories of Persona! Data are subject to stricter conditions, which may Include requiring the explicit consent of the Data Subject, For the purposes of this Policy Special Categories of Person Data will also include Criminal Records Data.

Data Protection Principles

We process Personal Data in accordance with the following data protection principles:

• We process Personal Data lawfully, fairly and In a transparent manner.
• We collect Personal Data only for specified, explicit and legitimate purposes.
• We process Personal Data only where It is adequate, relevant and limited to what is necessary for the purposes of processing.
• We keep accurate Personal Data and take all reasonable steps to ensure that inaccurate Personal Data Is rectified or deleted without delay on becoming aware of an inaccuracy.
• We keep Personal Data only for the period necessary for processing.
• We adopt appropriate measures to make sure that Personal Data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage, This includes secure lockable desks and cupboards, secure means of disposal and processes for ensuring that confidential information is not left accessible and/or unattended on PCs or desks.

We tell Individuals the reason for processing their Personal Data, how we use such Personal Data and the legal basis for processing in our privacy notices, We will not process Personal Data of individuals for other reasons. Where we rely on our legitimate interests as the basis for Processing Personal Data, we will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals,

We will update Personal Data promptly if an individual advises that his/her Personal Data has changed or is Inaccurate.

Personal Data gathered during the employment or the worker/contractor relationship is held In the individual’s personnel file (in both hard copy and electronic format), and on HR systems. The retention periods for which such HR-related Personal Data is held Is contained In our privacy notices.

Personal Data gathered from clients and other third parties, including suppliers Is held in files relating specifically to the client or the third party (In both hard copy and electronic format), the retention periods for which such Personal Data is held Is contained in our privacy notices.

Individual Rights

As a Data Subject, individuals have a number of rights in relation to their Personal Data.

Subject Access Requests

Individuals have the right to make a subject access request. If an individual makes a subject access request, we will tell them:

• whether or not their Personal Data is processed and if so why, the categories of Personal Data concerned and the source of the Personal Data if it is not collected from the individual;
• to whom their Personal Data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
• for how long their Personal Data is stored (or how that period is decided);
• their rights to rectification or erasure of Persona! Data, or to restrict or object to processing;
• their right to complain to the Information Commissioner If they think we have failed to comply with their data protection rights; and
• whether or not we carry out automated decision-making and the logic involved In any such decision-making.

We will also provide the individual with a copy of the Personal Data undergoing processing. This wili normally be in electronic form if the individual has made a request electronically, unless they agree otherwise.

To make a subject access request, the individual should send the request through to the Compliance Manager in writing. We may need to ask for proof of identification before the request can be processed. We will inform the individual if they need to verify their Identity and the documents required.

We will normally respond to a request within a period of one month from the date it is received. In some cases, such as where we process large amounts of the individual’s Personal Data, we may respond within three months of the date the request Is received. We will write to the individual within one month of receiving the original request to tell them if this is the case,

If a subject access request is manifestly unfounded or excessive, we are not obliged to comply with it, Alternatively, we can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which we have already responded. If an individual submits a request that is unfounded or excessive, we will notify them that this is the case and whether or not we will respond to It.

Other Rights

Individuals have a number of other rights in relation to their Personal Data. They can require us to:

• rectify inaccurate Personal Data;
• stop processing or erase Personal Data that is no longer necessary for the purposes of processing;
• stop processing or erase Personal Data if the individual’s Interests override our legitimate grounds for processing Personal Data (where we rely on legitimate interests as a reason for processing Personal Data);
• stop processing or erase Personal Data if processing is unlawful; and
• stop processing Personal Data for a period If Personal Data is inaccurate or if there Is a dispute about whether or not the individual’s interests override our legitimate grounds for processing the Personal Data.

To ask us to take any of these steps, the individual should send the request to the Compliance Manager in writing.

Data Security

We take the security of Personal Data seriously, We have Internal policies and controls in place to protect Personal Data against loss, accidental destruction, misuse or disclosure, and to ensure that Personal Data is not accessed, except by employees in the proper performance of their duties,

Where we engage third parties to process Personal Data on our behalf, such parties do so on the basis of written instructions from us, are under a duty of confidentiality and are obliged to implement appropriate technical and organizational measures to ensure the security of the Personal Data,

Impact Assessments

Some of the processing that we carry out may result in risks to privacy, Where processing would result in a high risk to individual’s rights and freedoms, we will carry out a data protection impact assessment to determine the necessity and proportionality of processing,

This will Include considering the purposes for which the activity Is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

Personal Data Breaches

If we discover that there has been a breach of Personal Data that poses a risk to the rights and freedoms of Individuals, we will report it to the Information Commissioner within 72 hours of discovery. We will record all Personal Data breaches regardless of their effect.

If the breach Is likely to result In a high risk to the rights and freedoms of individuals, we will tell affected Individuals that there has been a breach and provide them with Information about its likely consequences and the mitigation measures it has taken.

International Data Transfers

We will not transfer Personal Data to countries outside the EEA.

Individual Responsibilities

Employees are responsible for helping us keep their Personal Data upto date. Employees should let us know If Personal Data provided to us changes, for example if an employee moves to a new house or changes their bank details.

Employees may have access to the Personal Data of other employees and of our clients and other third parties, including suppliers, In the course of their employment. Where this is the case, we reiy on employees to help meet our data protection obligations to employees and to clients and such other third parties.

Employees who have access to Personal Data are required:

• to access only the Personal Data that they have authority to access and only for authorised purposes;
• not to disclose Personal Data except to individuals (whether inside or outside the firm) who have appropriate authorisation;
• to keep Personal Data secure (for example by complying with rules on access to the premises, computer access, including password protection, and secure file storage and destruction);
• not to remove Personal Data, or devices containing or that can be used to access Personal Data, from our premises without adopting appropriate security measures (such as encryption or password protection) to secure the Personal Data and the device;
• not to store Personal Data on local drives or on personal devices that are used for work purposes; and
• to report Personal Data breaches of which they become aware to the Compliance Manager immediately.

Training

We will provide training to ail Individuals about their data protection responsibilities as part of the induction process and at regular Intervals thereafter.

Individuals whose roles require regular access to Personal Data, or who are responsible for Implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them,

Audit

We are responsible for, and must be able to demonstrate, compliance with data protection principles. In order to do this, we will periodically review our systems and processes to ensure that we comply with this policy and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.

Breaches of this Policy

We take a strict approach to breaches of this policy. Failure to comply with this policy by employees may be treated as misconduct and addressed in accordance with the disciplinary policy. Serious or deliberate breaches may amount to gross misconduct which could result In dismissal without notice.