Data Protection Policy

The Company recognises the importance of the correct and lawful treatment of personal data. Any personal data, whether it is held on paper, computer or other media, will be subject to the appropriate legal safeguards as specified in the Data Protection Act 1998.

The Company fully adheres to the eight principles of the Data Protection Act. These principles specify the legal conditions that must be satisfied in relation to obtaining, handling, processing, transportation and storage of personal data. Employees and any others who obtain, handle, process, transport and store personal data for The Company must adhere to these principles.

The principles require that personal data shall:

  • Be processed fairly and lawfully and shall not be processed unless certain conditions are met;
  • Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose;
  • Be adequate, relevant and not excessive for those purposes;
  • Be accurate and, where necessary, kept up to date;
  • Not be kept for longer than is necessary for that purpose;
  • Be processed in accordance with the data subject’s rights;
  • Be kept secure from unauthorised or unlawful processing and protected against accidental loss, destruction or damage by using the appropriate technical and organisational measures;
  • And not be transferred to a country or territory outside the European Economic Area, unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data either through legislation or contractual provisions.

The Company Information Compliance Manager is responsible for ensuring compliance with the Data Protection Act and implementation of this policy.

Any questions or concerns about the interpretation or operation of this policy should be taken up in the first instance with the Information Compliance Manager for each company.

Any breach of this policy will be taken seriously and may result in formal action. Any employee who considers that the policy has not been followed in respect of personal data about themselves should raise the matter with their Line Manager or the relevant Information Compliance Manager in the first instance.

All individuals who are the subject of personal data held by the Company are entitled to:

  • Ask what information the company holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date.
  • Be informed what the company is doing to comply with its obligations under the 1998 Data Protection Act.

All employees are responsible for:

  • Checking that any personal data that they provide to the Company is accurate and up to date.
  • Informing the Company of any changes to information which they have provided, e.g. changes of address.

Employees and other subjects of personal data held by the Company have the right to access any personal data that is being kept about them on computer and also have access to paper-based data held in certain manual filing systems. This right is subject to certain exemptions which are set out in the Data Protection Act. Any person who wishes to exercise this right should make the request in writing to the relevant Information Compliance Manager.

Information that is already in the public domain is exempt from the 1998 Act. This would include, for example, information on staff contained within externally circulated publications. Any individual who has good reason for wishing details in such publications to remain confidential should contact the relevant Information Compliance Manager

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