Data Privacy Policy
Beaumont Stays Ltd
Beaumont Stays Ltd (Referred to as “We”, “Us”, “Our” from here
forward) understands that your privacy is important to you
and that you care about how your personal data is used.
We respect and value the privacy of everyone who visits
Our website: www.beaumontstays.co.uk will only collect and
use personal data in ways that are described here and in
a way that is consistent with Our obligations and your rights
under the regulation, the General Data Protection
Regulations 2018.
By providing your Personal Data, you are affirming that you
are over 18 years of age.
For the purpose of the General Data Protection Regulations
2018, Company Name are the data controller and are
registered with the Information Commissioner’s Office.Data Privacy Policy
3Roles and Responsibilities:
Company’s Data Protection Officer is: Kate Beaumont
Email: hello@beaumontstays.com
Office Tel No: 07786332445
In Writing: Company Address: 86-90 Paul St, London, EC2A 4NE
Please read this Privacy Policy carefully and ensure that
you understand it. Your acceptance of this Privacy Policy
is deemed to occur upon your first use of Our Site. If you
do not accept and agree with this Privacy Policy, you must
stop using Our Site immediately.
If you are not happy with any aspect of how We obtain,
hold or use your personal data then you have a right to
make a complaint to the Information Commissioners Office
(ICO) – www.ico.org.uk - We would however prefer that
you contact Us first and be given an opportunity to resolve
any issue that you might have.
The Regulation 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.
4This Policy sets out the procedures that are to be followed
when dealing with personal data. The procedures and
principles set out herein must be followed at all times by
Company Name , its employees, agents, contractors, or
other parties working on behalf of Company Name .
Company Name is committed not only to the letter of the
law but also to the spirit of the law and places a high
premium 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.
SUMMARY
Beaumont Stays will at all times :
1. Be transparent about what information:
a. We collect
b. Why we collect it
c. How we store it
d. Where we store it
e. What we do with it
f. When we dispose it
g. How we dispose it
2. Have measures in place to protect your personal data
and keep secure;
3. Respect your rights under GDPR and aim to give you
control over your own personal data;
4. Cease communication with you if requested to do so
51.1. This Policy aims to ensure compliance with the
Regulation. The Regulation sets out the following
principles with which any party handling personal
data must comply. All personal data must be:
1.1.1. Processed lawfully, fairly and in a transparent
manner in relation to the data subject.
1.1.2. Collected for specified, explicit and legitimate
purpose 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.
1.1.3. Adequate, relevant and limited to what is
necessary in relation to the purposes for which it is
processed.
1.1.4. 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 they are
processed, is erased or rectified without delay.1. The Data Protection Principles
61.1.5.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 Regulation in order to
safeguard the rights and freedoms of the data
subject.
1.1.6.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.
72.1. The Regulation seeks to ensure that personal data is
processed lawfully, fairly, and transparently, without
adversely affecting the rights of the data subject.
The Regulation states that processing of personal
data shall be lawful if at least one of the following
applies:2. Lawful Fair, and Transparent Data
Processing
2.1.1. The data subject has given consent to the
processing of his or her personal data for one
or more specific purposes.
2.1.2. 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.
2.1.3. Processing is necessary for compliance with a
legal obligation to which the controller is
subject.
2.1.4. Processing is necessary to protect the vital
interests of the data subject or of another
natural person.
2.1.5. 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
controller.
2.1.6.Processing is necessary for the purposes of the
legitimate interests pursued by the 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.
83.1 . Company name collects and processes the personal
data set out in Part 20 of this Policy. This may include
personal data received directly from data subjects
(for example, contact details used when a data
subject communicates with us).
3.2. Company Name only processes personal data for
the specific purposes set out in Part 20 of this Policy
(or for other purposes expressly permitted by the
Regulation). The purposes for which we process
personal data will be provided to data subjects
either via our ‘Seller/Investor Information Pack’,
which contains a copy of our ‘Client Data
Privacy Guide’ or a link to our company Data
Privacy, Cookie & Retention Policy either at the
time that their personal data is collected via a
‘Contact Us’ section (must tick to indicate they
have read), or as soon as possible (not more than one
calendar month) after collection where it is obtained
from a third party.
3.3. A link to a copy of our Data Privacy, Cookie &
Retention Policy is available to at any time, at the
bottom of each page of our website: Company
website.3. Processed for Specified, Explicit, and
Legitimate Purposes.
94.1. Company Name will only collect and process personal
data for and to the extent necessary for the specific
purpose(s) informed to data subjects as under Part 3,
above.
5.1. Company Name shall ensure that all personal data
collected and processed is kept accurate and
up-to-date. The accuracy of data shall be checked
when it is collected and at 12 monthly intervals
thereafter. Where any inaccurate or out-of-date data
is found, all reasonable steps will be taken without
delay to amend or erase that data, as appropriate.4. Adequate, Relevant, and Limited
Data Processing
5. Accuracy of Data and Keeping Data
Up to Date
107.1. Company Name shall ensure that all personal data
collected and processed is kept secure and
protected against unauthorised or unlawful
processing and against accidental loss, destruction
or damage. Further details of the data protection and
organisational measures, which shall be taken, are
provided in Parts 22 to 28 of this Policy.7. Secure Processing 6.1. Company Name shall not keep personal data for any
longer than is necessary in light of the purposes for
which that data was originally collected and
processed. When the data is no longer required,
all reasonable steps will be taken to erase it
without delay.
6.2. For full details of the Companies approach to data
retention, including retention periods for specific
personal data types held by Company Name , please
refer to our Data Retention Policy section later in this
document.6. Data Retention
118.1. Company Name’s Data Protection Officer is Name
Email: Email Address.
8.2. The Data Protection Officer shall be responsible
for overseeing the implementation of thisPolicy and
for monitoring compliance with this Policy,
Company Name’s other data protection-related
policies, and with the GDPR and other applicable data
protection legislation. 8. Accountability
8.2.1. Company Name shall keep written internal
records of all personal data collection, holding,
and processing, which shall incorporate the
following information:
8.2.2. The name and details of Company Name its
Data Protection Officer, and any
applicable third-party data processors.
8.2.3 The purposes for which Company Name
processes personal data.
8.2.4. Details of the categories of personal data
collected, held, and processed by Company
Name ; and the categories of data subject to
which is personal data.
8.2.5. relates. Details (and categories) of any third
parties that will receive personal data from
{enter your company initials here }.
8.2.6 Details of any transfers of personal data to
non-EEA countries including all mechanisms
and security safeguards.
8.2.7. Details of how long personal data will be
retained by Company Name and
8.2.8. Detailed descriptions of all technical and
organisational measures taken by Company
Name to ensure the security of personal data.
129.1. Company Name 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 Regulations.
9.2. Privacy Impact Assessments shall be overseen by
Company Name’s data protection officer and
shall address the following areas of importance:9. Data Protection Impact Assessments
9.2.1. The types of personal data that will be
collected held and processed.
9.2.2. The purpose(s) for which personal data will be used.
9.2.3. The companies objectives.
9.2.4. How personal data is to be used.
9.2.5. Any parties (internal or external) who may be
consulted.
9.2.6. The necessity and proportionality of the data
processing with respect to the purpose(s) for
which it is being processed.
9.2.7. Risks posed to data subjects.
9.2.8. Risks posed both within and to Company Name;
and
9.2.9. Proposed measures to minimise and handle
identified risks.
1310.1. The GDPR sets out the following rights applicable
to data subjects (please refer to the parts of this policy
indicated for further details):10. The Rights of Data Subjects
10.1.1. The right to be informed (Part 11);
10.1.2. The right of access (Part 12);
10.1.3. The right to rectification (Part 13);
10.1.4. The right to erasure (also known as the ‘right to be
forgotten’) (Part 14);
10.1.5. The right to restrict processing (Part 15);
10.1.6. The right to data portability (Part 16);
10.1.7. The right to object (Part 17);
10.1.8. Rights with respect to automated
decision-making and profiling (Parts 18 and 19).
1411.1. Company Name shall ensure that the following
information is provided to every data subject
when personal data is collected:11. Keeping Data Subjects Informed
11.1.1. Details of {enter your company initials here}
including, but not limited to, the identity of
{Name (Position)}, its Data Protection Officer;
11.1.2. The purpose(s) for which the personal data is
being collected and will be processed (as
detailed in Part 20 of this Policy) and the legal
basis justifying that collection and processing;
11.1.3. Where applicable, the legitimate interests upon
which {enter your company initials here} is
justifying its collection and processing of the
personal data;
11.1.4. Where the personal data is not obtained
directly from the data subject, the categories
of personal data collected and processed;
11.1.5. Where the personal data is to be transferred
to one or more third parties, details of those
parties;
11.1.6. 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 concerning such third country data
transfers);
11.1.7. Details of the length of time the personal data
will be held by {enter your company initials here}
(or, where there is no predetermined period,
details of how that length of time will be
determined);
1511.1.8. Details of the data subject’s rights under the
Regulation;
11.1.9. Details of the data subject’s right to withdraw
their consent to {enter your company initials
here}’s processing of their personal data at
any time;
11.1.10. Details of the data subject’s right to complain
to the Information Commissioner’s Office
(the ‘supervisory authority’ under the Regulation);
11.1.11. Where applicable, details of any legal or
contractual requirement or obligation
necessitating the collection and processing of
the personal data and details of any
consequences of failing to provide it;
11.1.12. Details of any automated decision-making that
will take place using the personal data
(including but not limited to profiling), including
information on how decisions will be made, the
significance of those decisions and any
consequences.
1611.2.1. Where the personal data is obtained from
the data subject directly, at the time of
collection;
11.2.2. Where the personal data is not obtained from
the data subject directly (i.e. from another party):
11.2.2.1. If the personal data is used to communicate
with the data subject, at the time of the
first communication; or
11.2.2.2. If the personal data is to be disclosed to
another party, before the personal data is
disclosed; or
11.2.2.3. In any event, not more than one month
after the time at which {enter your
company initials here} obtains the personal
data.11.2. The information set out above in Part 10.1 shall be
provided to the data subject at the following
applicable time:
1712.1. A data subject may make a subject access request
(“SARs”) at any time to find out more about the
personal data which Company Name holds about
them. Company Name is normally required to respond
to SARs within one month of receipt (this can be
extended by up to two months in the case of complex
and/or numerous requests, and in such cases the data
subject shall be informed of the need for the
extension).
12.2. All subject access requests received must be
forwarded to Officer’s Name, Company Name’s Data
Protection Officer. Email: Email Address.
12.3. Company Name does not charge a fee for the
handling of normal SARs. Company Name 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.12. Data Subject Access
1813.1. If a data subject informs Company Name that
personal data held Company Name is
inaccurate or incomplete, requesting that it be
rectified, the personal data in question shall be
rectified, and the data subject informed of that
rectification, within one month of receipt the data
subject’s notice (this can be extended by up to
two months in the case of complex requests, and in
such cases the data subject shall be informed of the
need for the extension).
13.2. In the event that any affected personal data has
been disclosed to third parties, those parties shall
be informed of any rectification of that personal data.13. Rectification of Personal Data
1914.1. Data subjects may request that Company Name
erases the personal data it holds about them in the
following circumstances:
14.2. Unless Company Name 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 (this can be extended by up to two
months in the case of complex requests, and in such
cases the data subject shall be informed of the need
for the extension).
14.3. In the event that any personal data that is to be erased
in response to a data subject 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).14. Erasures of Personal Data
14.1.1. It is no longer necessary for Company Name to
hold that personal data with respect to the
purpose for which it was originally collected or
processed.
14.1.2. The data subject wishes to withdraw their consent
to Company Name holding and processing their
personal data.
14.1.3. The data subject objects to Company Name
holding and processing their personal data
(and there is no overriding legitimate interest to
Company Name to continue doing so) (see Part
17 of this Policy for further details concerning data
subjects’ rights to object).
14.1.4. The personal data has been processed
unlawfully.
14.1.5. The personal data needs to be erased in order
for Company Name to comply with a particular
legal obligation.
2015.1. Data subjects may request that Company Name
ceases processing the personal data it holds
about them. If a data subject makes such a request,
Company Name shall retain only the amount of
personal data pertaining to that data subject that is
necessary to ensure that no further processing of their
personal data takes place.
15.2. 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).15. Restriction of Personal Data
Processing
2116.1. Company Name processes personal data using
automated means ( Change the apps listed below
based on what you are using for your company) :16. Data Portability
16.1.1. Asana - Customer Relationship Management
system
16.1.2. Zeevou – Property Management System
16.1.3. Google Drive – Secure Data Storage System
16.1.4. Active Campaign – Automated Email Response
system
16.1.5. Calendly – Appointment booking system
16.1.6. Wordpress – Website(s) – Contact Us and/or
Request further information Forms
16.1.7. Stripe – Receive payment for services
16.1.8. Xero –Send Invoices for payment
16.1.9. Dropbox – File transfer system
16.1.10. Credas – Identity and Document Authentication
2216.2. Where data subjects have given their consent to
Company Name to process their personal data in such
a manner or the processing is otherwise required for
the performance of a contract between Company
Name and the data subject, data subjects have the
legal right under the Regulation to receive a copy of
their personal data and to use it for other purposes
(namely transmitting it to other data controllers,
e.g. other organisations).
16.3. To facilitate the right of data portability, Company
Name shall make available all applicable personal
data to data subjects in the following format(s):
16.4. Where technically feasible, if requested by a data
subject, personal data shall be sent directly to another
data controller.
16.5. All requests for copies of personal data shall be
complied with within one month of the data subject’s
request (this can be extended by up to two months
in the case of complex requests in the case of
complex or numerous requests, and in such cases
the data subject shall be informed of the need for
the extension).16.3.1. Exported data in csv file format;
16.3.2. Access to Company Name Registration
Agreements, Documents and Forms via upon
request, Google Drive shared access to file;
2317.1. Data subjects have the right to object to Company
Name processing their personal data based on
legitimate interests (including profiling), direct
marketing (including profiling).
17.2. Where a data subject objects to Company Name
processing their personal data based on its legitimate
interests, Company Name shall cease such
processing forthwith, unless it can be demonstrated
that Company Name’ s legitimate grounds for such
processing override the data subject’s interests, rights
and freedoms; or the processing is necessary for the
conduct of legal claims.
17.3. Where a data subject objects to Company Name
processing their personal data for direct marketing
purposes, Company Name shall cease such
processing forthwith.17. Objections to Personal
Data Processing
2418.1. In the event that Company Name uses personal data
for the purposes of automated decision and those
decisions have a legal (or similarly significant effect)
on data subjects, data subjects have the right to
challenge to such decisions under the Regulation,
requesting human intervention, expressing their own
point of view, and obtaining an explanation of the
decision from Company Name .
18.2. The right described in Part 18.1 does not apply in
the following circumstances:18. Automated Decision-Making
18.2.1. The decision is necessary for the entry into, or
performance of, a contract between
{enter your company initials here} and the
data subject;
18.2.2. The decision is authorised by law; or
18.2.3. The data subject has given their explicit consent.
2519.1. Company Name does not use personal data for
profiling purposes. If it did the following would apply:19. Profiling
19.1.1. Clear information explaining the profiling will
be provided, including its significance and the
likely consequences
19.1.2. Appropriate mathematical or statistical
procedures will be used;
19.1.3. Technical and organisational measures necessary
to minimise the risk of errors and to enable
such errors to be easily corrected shall be
implemented; and
19.1.4. All personal data processed for profiling purposes
shall be secured in order to prevent discriminatory
effects arising out of profiling (see Parts 22 to 28 of
this Policy for more details on data security).
2620.1. The following personal data may be collected, held,
and processed by { BSL }:
21.1. You may receive marketing communications from
US if you have:
21.1.1. Requested information, purchased goods or
services from Us. Or
21.1.2. Completed one of Our ‘Contact Us’ forms
and ticked the box requesting information.
21.1.3. Not opted out of receiving marketing from Us
{You can opt–out at any time by using the ‘Unsubscribe me’
option at the bottom of the email (Active Campaign) or
by emailing Us at Customer Care Email Address and typing
STOP in the subject line.}20. Personal Data
21. Marketing CommunicationsContact Type Data Collected Purpose of Data
Client- Buyer
IndividualFull Name
Home Address
DOB
Contact Number(s)
Proof of Identification
Proof of AddressProvide business service(s)
Fulfill obligations under Money
Laundering Regulations
Receive payment for services
provided (where applicable)
Guests Full Name
Identification card(s)
Contact Number(s)
Documents to prove
that their stay is aligned
with government
guidelinesProvide business service(s)
Receive payment for services
provided (where applicable)
2722.1. Company Name shall ensure that all its employees,
agents, contractors, or other parties working on its behalf
comply with the following when working with personal data:22. Data Protection Measures
22.1.1. No personal data is to be automatically sent
via an email(s) system unless expressly requested
by the data owner.
22.1.2. All emails containing personal data must be
marked “confidential”;
22.1.3. Where 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. Hardcopies should
be shredded (in {Opulent Living} office before
recycling), and electronic copies should be
deleted securely using {‘CleanMyMac3’}
(where held on Director(s) Laptop) or third party
system deletion.
22.1.4. Personal data may be transmitted over
secure networks only; transmission over unsecured
networks is not permitted in any circumstances;
22.1.5. Personal data may not be transmitted over a
wireless network if there is a wired alternative
that is reasonably practicable;
22.1.6. Personal data should not be transferred via email,
however if this happens, whether sent or received,
it 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 ‘CleanMyMac3’ (where
held on Director(s) Laptop)};
2822.1.7. Where Personal data is to be sent by facsimile
transmission it should be marked as
“confidential” and the recipient should be
informed in advance of the transmission and
should be waiting by the fax machine to
receive the data;
22.1.8. Where Personal data is to be transferred in
hardcopy form it should be marked as
“confidential” and passed directly to the
recipient or sent using Royal Mail (receipt
signature required) Postal Service;
22.1.9. No personal data may be shared informally
and if an employee, agent, sub-contractor, or
other party working on behalf of Company
Name requires access to any personal data
that they do not already have access to, such
access should be formally requested from
Officer’s Name (Data Protection Officer).
22.1.10. All hardcopies of personal data, along with
any electronic copies stored on physical,
removable media should be stored securely
in either the locked filing cabinet or locked,
fire proof safe.
2922.1.11. No personal data may be transferred to any
employees, agents, contractors, or other
parties, whether such parties are working on
behalf of {enter your company initials here}
or not, without the authorisation of Officer’s
Name (Data Protection Officer).
22.1.12. 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;
22.1.13. 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.
3023.1. Company Name shall ensure that the following
measures are taken with respect to the storage
of personal data:23. Data Security- Storage
23.1.1. {All electronic copies of personal data should
be stored securely using an encrypted and
password protected file on Company Name
Mac Laptops.}
23.1.2. {All hardcopies of personal data must be
stored in the locked filing cabinet in the
Company Name office all electronic copies
stored on physical, removable media should be
stored in the locked, fireproof safe located in the
{enter your company initials here} office.}
23.1.3. Personal data may be stored on a mobile
` device which must have a secure password
system in place (including, but not limited to,
laptops, tablets and smartphones), for the
purpose of recording a copy of an original
document to prove client identification,
home address, proof of funds or proof of source
of funds, and within 24 hours transferred to an
encrypted and password protected desktop file
and deleted from the device which captured the
image, as well as any ‘back up’ files of data
fulfilled in the time period since the image(s)
were captured.
3123.1.4. 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 {enter your
company initials here} where the party in
question has agreed to comply fully with the
letter and spirit of this Policy and of the Regulation
(which may include demonstrating to
{enter your company initials here} that all suitable
technical and organisational measures have
been taken);
23.1.5. 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.
3223.1.6. Under no circumstances should any
passwords be written down or shared between
any employees, agents, contractors, or other
parties working on behalf of Company Name,
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;
23.1.7. Where personal data held by Company Name
is used for marketing purposes, it shall be the
responsibility of Officer’s Name (Data Protection
Officer) to ensure that no data subjects have
added their details to any marketing preference
databases including, but not limited to, the
Telephone Preference Service, the Mail
Preference Service, the Email Preference Service,
and the Fax Preference Service. Such details
should be checked at least annually.
3324.1. 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 {enter your company
initials here}’s Data Retention Policy below.24. Data Security- Disposal
25.1. Company Name shall ensure that the following
measures are taken with respect to the use of
personal data:25. Data Security- Use of Personal Data
25.1.1. No personal data may be shared informally and
if an employee, agent, sub-contractor, or other
party working on behalf of Company Name
requires access to any personal data that they
do not already have access to, such access
should be formally requested from Officer’s
Name – The Data Protection Officer -
Email: Email Address ;
25.1.2. No personal data may be transferred to any
employees, agents, contractors, or other parties,
whether such parties are working on behalf
Company Name or not, without the authorisation
of Officer’s Name – The Data Protection Officer –
Email: Email Address;
3425.1.1. No personal data may be shared informally and
if an employee, agent, sub-contractor, or other
party working on behalf of Company Name
requires access to any personal data that they
do not already have access to, such access
should be formally requested from Officer’s
Name – The Data Protection Officer -
Email: Email Address ;
25.1.2. No personal data may be transferred to any
employees, agents, contractors, or other parties,
whether such parties are working on behalf
Company Name or not, without the authorisation
of Officer’s Name – The Data Protection Officer –
Email: Email Address;
25.1.3. 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;
25.1.4. 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
25.1.5. Where personal data held by Company Name
is used for marketing purposes, it shall be
the responsibility of Officer’s Name – The Data
Protection Officer – Email: Email Address 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.
3526.1. Company Name shall ensure that the following
measures are taken with respect to IT and
information security:26. Data Security- IT Security
26.1.1. 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.
26.1.2.Under no circumstances should any passwords
be written down or shared between any
employees, agents, contractors, or other parties
working on behalf of Company Name ,
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.
26.1.3. All software (including, but not limited to,
applications and operating systems) shall be kept
up-to-date. Company Name’s Director’s shall be
responsible for installing any and all security-
related updates as soon as reasonably and
practically possible, unless there are valid
technical reasons not to do so; and
26.1.4.No software may be installed on any
Company-owned computer or device without
the prior approval of the Officer’s Name – The Data
Protection Officer –Email: Email Address .
3627.1. Company Name ensure that the following measures
are taken with respect to the collection,holding, and
processing of personal data:27. Organisational Measures
27.1.1. All employees, agents, contractors, or other
parties working on behalf Company Name
shall be made fully aware of both their individual
responsibilities and Company Name’s
responsibilities under the Regulation and
under this Policy, and shall be provided with a
copy of this Policy;
27.1.2. Only employees, agents, sub-contractors,
or other parties working on behalf of Company
Name 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 Company Name ;
27.1.3. All employees, agents, contractors, or other
parties working on behalf of Company Name
handling personal data will be appropriately
trained to do so;
27.1.4. All employees, agents, contractors, or other
parties working on behalf of Company Name
handling personal data will be appropriately
supervised;
3727.1.5. Methods of collecting, holding and
processing personal data shall be regularly
evaluated and reviewed;
27.1.6. The performance of those employees, agents,
contractors, or other parties working on behalf
of Company Name handling personal data shall
be regularly evaluated and reviewed;
27.1.7. All employees, agents, contractors, or
other parties working on behalf of Company
Name handling personal data will be bound
to do so in accordance with the principles of the
Regulation and this Policy by contract;
27.1.8. All agents, contractors, or other parties
working on behalf of Company Name 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 Company Name arising out of this Policy
and the Regulation;
27.1.9. I) Where any agent, contractor or other
party working on behalf of Company
Name handling personal data fails in their
obligations under this Policy that party
shall indemnify and hold harmless Company
Name against any costs, liability, damages,
loss, claims or proceedings which may arise
out of that failure.
3828.1. Company Name does not transfer any personal data
to any country outside the EEA, unless:
28.2. The transfer is made with the informed consent of the
relevant data subject(s);
28.3. The transfer is necessary for the performance of a
contract between the data subject and Company
Name (or for pre-contractual steps taken at the
request of the data subject);
28.4. The transfer is necessary for important public
interest reasons;
28.5.The transfer is necessary for the conduct of legal claims;
28.6. 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;
28.7. The transfer is made from a register that, under UK
or EU law, is intended to provide information to
the public and which is open for access by the
public in general or otherwise to those who are
able to show a legitimate interest in accessing
the register.28. Transferring Personal Data to a
Country outside the EEA
3929.1. All personal data breaches must be reported
immediately to Company Name’s Data Protection
Officer Officer’s Name.
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, andin 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 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. Data Breach Notification
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 Company
Name’s Data Protection Officer (or other
contact point where more information can
be obtained);
29.4.4. The likely consequences of the breach;
29.4.5. Details of the measures taken, or proposed to
be taken, by { enter your company initials here }
to address the breach including, where
appropriate, measures to mitigate its
possible adverse effects.
4030.1. Our website may include links to ‘third party
websites’, applications or plugins. By clicking on
any of those links you are enabling those
connections and that may allow third party
websites to collect data about you.
30.2. We do not control those third-party websites
and cannot be held responsible for their privacy
policies. We advices that if you leave Our website,
that you read privacy notices for all other websites
that you may visit. For more information,please refer
to Our Data Retention Policy section later in
this document.
31.1. You are able to set your browser to refuse some
or all cookies. You can also set to alert you when
a website sets or adds cookies. If you disable or
refuse cookies, some parts of Our website may
become inaccessible or fail to function as meant to.
You can gain more information about cookies at:
Wikipedia -Guide -HTTP Cookies. For more information,
please refer to Our Cookie Policy section later
in this document.
32.1. This Policy shall be deemed effective as of
{enter date your policy went live here }.
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 & authorised
by Name: Kate Beaumont
Position: Director
Date: 30.09.2025
Review Date: 30.09.2026
Signature:30. Third Party Links
31. Cookies
32. Implementation of Policy