YOUR COMPANY NAME

We request your consent to use the personal data you enter below. This permits us to fulfill our obligations to you. At anytime you can exercise your RIGHTS regarding your personal data that we may have in our possession. We never request excessive personal data/information just for the sake of it and are able upon request to justify the reason as to why we are requesting such data/information and its purpose.

If you are under our minimum age of consent which is 16 years of age, your details will be permanently deleted within 5 working days if it has not been forwarded by your Guardian.

As defined by The General Data Protection Regulation (GDPR), a data breach is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. This includes breaches that are the result of both accidental and deliberate causes.

You can contact us via traditional post directly to our appointed GDPR Registrar acting on our behalf as our registered European GDPR Secretariat.

Our GDPR Secretariats duties are to view your submission and submit them to us, where we will take the necessary steps in answering you accordingly in-line with the GDPR Regulations and the protection of your personal data.

To avoid unsolicited incoming postal mail,  please request our postal address via our DATA PRIVACY SECRETARIAT contact form below.

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Our Secretariat has declared our compliance as a non-EU Entity to all the applicable EU (GDPR) Supervisory Authorities. Following is a list of all EU (GDPR) Supervisory Authorities:

INTRODUCTION

As a non-EU based organization, we the Entity have chosen to demonstrate compliance in accordance with the GDPR. This policy sets out our commitment in providing assurance that any personal data, including special category personal data, which we process, is carried out in compliance with the GDPR and that best-data-practices are embedded in the culture of our staff and our organization. The key data protection policies and procedures as per the General Data Protection Regulation 2016/679 (GDPR) include:

• record of processing activities
• privacy notices (website, clients, employees)
• personal data breach reporting process
• breach register
• data retention policy
• data subject rights procedure
• data protection impact assessment process
• information and security policy

SCOPE

This policy applies to all personal data processed by Entity and is part of Entity’s approach to compliance with the GDPR as a non-EU based organization. All Entity staff will comply with this policy and failure to comply may lead to disciplinary action for misconduct, including dismissal.

DATA PROTECTION PRINCIPLES

Entity complies with the data protection principles set out below. When processing personal data, it ensures that:

• it is processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’)
• it is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’)
• it is all adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)
• it is all accurate and, where necessary, kept up to date and that reasonable steps will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’)
• it is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’)
• it is 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 (‘integrity and confidentiality’)

Entity will facilitate any request from a data subject who wishes to exercise their rights under data protection law as appropriate, always communicating in a concise, transparent, intelligible and easily accessible via this form and reply within one calendar month as permitted by the data privacy regulations.

PROCESS/PROCEDURES/GUIDANCE

Entity will:

• ensure that the legal basis for processing personal data is identified in advance and that all processing complies with the law
• not do anything with your data that you would not expect given the content of this policy and the fair processing or privacy notice
• ensure that appropriate privacy notices are in place advising staff and others how and why their data is being processed, and, in particular, advising data subjects of their rights
• only collect and process the personal data that it needs for purposes it has identified in advance
• ensure that, as far as possible, the personal data it holds is accurate, or a system is in place for ensuring that it is kept up to date as far as possible
• only hold onto personal data for as long as it is needed, after which time Entity will securely erase or delete the personal data
• ensure that appropriate security measures are in place to ensure that personal data can only be accessed by those who need to access it and that it is held and transferred securely

Entity will ensure that all staff who handle personal data on its behalf are aware of their responsibilities under this policy and other relevant data protection and information security policies, and that they are adequately trained and supervised.

DATA SUBJECT RIGHTS

Entity has processes in place to ensure that it can facilitate any request made by an individual to exercise their rights under data protection law. All staff have received training and are aware of the rights of data subjects. Staff can identify such a request and know who to send it to. All requests will be considered without undue delay and within one month of receipt as far as possible. Such rights include:

Access Request: the right to request information about how personal data is being processed, including whether personal data is being processed and the right to be allowed access to that data and to be provided with a copy of that data along with the right to obtain the following information:

• the purpose of the processing
• the categories of personal data
• the recipients to whom data has been disclosed or which will be disclosed
• the retention period
• the right to lodge a complaint with the Supervisory Authority
• the source of the information if not collected direct from the subject, and
• the existence of any automated decision making

Correction Request: the right to allow a data subject to rectify inaccurate personal data concerning them.

Erasure Request: the right to have data erased and to have confirmation of erasure, but only where:

• the data is no longer necessary in relation to the purpose for which it was collected, or
• where consent is withdrawn, or
• where there is no legal basis for the processing, or
• there is a legal obligation to delete data

Restriction Request: the right to ask for certain processing to be restricted in the following circumstances:

• if the accuracy of the personal data is being contested, or
• if our processing is unlawful but the data subject does not want it erased, or
• if the data is no longer needed for the purpose of the processing but it is required by the data subject for the establishment, exercise or defence of legal claims, or
• if the data subject has objected to the processing, pending verification of that objection

Portability Request: the right to receive a copy of personal data which has been provided by the data subject and which is processed by automated means in a format which will allow the individual to transfer the data to another data controller. This would only apply if Entity is processing the data using consent or on the basis of a contract.

Objection Request: the right to object to the processing of personal data relying on the legitimate interests processing condition unless Entity can demonstrate compelling legitimate grounds for the processing which override the interests of the data subject or for the establishment, exercise or defence of legal claims.

OptOut Request: the right given to a data subject to optout where a user takes action in order to withdraw their consent to the processing of their personal data.

Right To Be Informed Request: the right to request information based on Art.13 and Art.14 of the GDPR where any processing of personal data is lawful, fair, transparent and where a data subject can request evidence of GDPR conformity.

SPECIAL CATEGORY PERSONAL DATA

This includes the following personal data revealing:

• racial or ethnic origin
• political opinions
• religious or philosophical beliefs
• trade union membership
• the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person
• an individual’s health
• a natural person’s sex life or sexual orientation
• criminal convictions or offences

Where Entity processes special category data of clients and third parties as is necessary to provide products/services for the establishment, exercise or defence of legal claims.

Entity processes special category data of employees as is necessary to comply with employment and social security law. This policy sets out the safeguards we believe are appropriate to ensure that we comply with the data protection principles set out above. Entity also has a data retention policy which sets out how long special category data will be held onto.

RESPONSIBILITY FOR THE PROCESSING OF PERSONAL DATA

Entity takes full responsibility in the protection of your personal data. If you have any concerns or wish to exercise any of your rights under the GDPR, then please use the options provided in this form.

COMPLIANCE POLICY CORRECTIONS

Entity welcomes data subject contribution from EU-Citizens, in improving its compliance policy, where it may fall short in line with the GDPR. Such contributions can be submitted via EMAIL above.

MONITORING AND REVIEW OF POLICY

This policy was last updated on 1 December 2022 and shall be regularly monitored and reviewed, at least every 12 months.