We take privacy and confidentiality seriously. We therefore comply with the principles of the 
United Kingdom Data Protection Act 1998 and General Data Protection Regulations.

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We are registered under the Information Commissioner’s Office under registration number ZB238836.

 

Our Data Protection Privacy Policy is as follows:

1.    Introduction
This Policy sets out the obligations of Comharra Solutions Ltd a company registered in United 
Kingdom under number SC639356 whose registered office is at Unit 3000 Gower Street, Academy Park, 
Glasgow, Lanarkshire, Scotland, G51 1PR (“the Company”) regarding data protection and the rights of 
Clients, Client Employees, Staff Members and Consumers (“data subjects”) in respect of their 
personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

 

The GDPR 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.

This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, 
and disposal of personal data. The procedures and principles set out herein must be followed at all 
times by the Company, its employees, agents, contractors, or other parties working on behalf of the 
Company.

The Company is committed not only to the letter of the law, but also to the spirit of the law and 
places high importance 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.

2.    The Data Protection Principles

This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles 
with which any party handling personal data must comply. All personal data must be:
•     Processed lawfully, fairly, and in a transparent manner in relation to the data 
subject.

•     Collected for specified, explicit, and legitimate purposes 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.
•     Adequate, relevant, and limited to what is necessary in relation to the purposes for 
which it is processed.
•     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 it is 
processed, is erased, or rectified without delay.
•     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 GDPR in 
order to safeguard the rights and freedoms of the data subject.
•     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.

3.    The Rights of Data Subjects

The GDPR sets out the following rights applicable to data subjects (please refer to the parts of 
this policy indicated for further details):
•     The right to be informed (Part 12).
•     The right of access (Part 13);
•     The right to rectification (Part 14);
•     The right to erasure (also known as the ‘right to be forgotten’) (Part 15);
•     The right to restrict processing (Part 16);
•     The right to data portability (Part 17);
•     The right to object (Part 18); and
•     Rights with respect to automated decision-making and profiling (Parts 19 and 20).

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4.    Lawful, Fair, and Transparent Data Processing

The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, 
without adversely affecting the rights of the data subject. The GDPR states that processing of 
personal data shall be lawful if at least one of the following applies:
•     The data subject has given consent to the processing of their personal data for one 
or more specific purposes;
•     The 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 with them;
•     The processing is necessary for compliance with a legal obligation to which the data 
controller is subject;
•     The processing is necessary to protect the vital interests of the data subject or of 
another natural person;
•     The 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 data controller; or
•     The processing is necessary for the purposes of the legitimate interests pursued by 
the data 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.
•     If the personal data in question is “special category data” (also known as 
“sensitive personal data”) (for example, data concerning the data subject’s race, ethnicity, 
politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, 
sex life, or sexual orientation), at least one of the following conditions must be met:
•     The data subject has given their explicit consent to the processing of such data for 
one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);
•     The processing is necessary for the purpose of carrying out the obligations and 
exercising specific rights of the data controller or of the data subject in the field of 
employment, social security, and social protection law (insofar as it is authorised by EU or EU 
Member State law or a collective agreement pursuant to EU Member State law which provides for 
appropriate safeguards for the fundamental rights and interests of the data subject);
•     The processing is necessary to protect the vital interests of the data subject or of 
another natural person where the data subject is physically or legally incapable of giving 
consent;      

•     The data controller is a foundation, association, or other non-profit body with a 
political, philosophical, religious, or trade union aim, and the processing is carried out in the 
course of its legitimate activities, provided that the processing relates solely to the members or 
former members of that body or to persons who have regular contact with it in connection with its 
purposes and that the personal data is not disclosed outside the body without the consent of the 
data subjects;
•     The processing relates to personal data which is clearly made public by the data 
subject;
•     The processing is necessary for the conduct of legal claims or whenever courts are 
acting in their judicial capacity;
•     The processing is necessary for substantial public interest reasons, on the basis of 
EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the 
essence of the right to data protection, and shall provide for suitable and specific measures to 
safeguard the fundamental rights and interests of the data subject;
•     The processing is necessary for the purposes of preventative or occupational 
medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the 
provision of health or social care or treatment, or the management of health or social care systems 
or services on the basis of EU or EU Member State law or pursuant to a contract with a health 
professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;
•     The processing is necessary for public interest reasons in the area of public 
health, for example, protecting against serious cross-border threats to health or ensuring high 
standards of quality and safety of health care and of medicinal products or medical devices, on the 
basis of EU or EU Member State law which provides for suitable and specific measures to safeguard 
the rights and freedoms of the data subject (in particular, professional secrecy); or
•     The processing is necessary for archiving purposes in the public interest, 
scientific or historical research purposes, or statistical purposes in accordance with Article 
89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim 
pursued, respect the essence of the right to data protection, and provide for suitable and specific 
measures to safeguard the fundamental rights and the interests of the data subject.

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5.    Specified, Explicit, and Legitimate Purposes

The Company collects and processes the personal data set out in Part 21 of this Policy. This 
includes:
•     Personal data collected directly from data subjects
•     Personal data obtained from third parties.
•     The Company only collects, processes, and holds personal data for the specific 
purposes set
out in Part 21 of this Policy (or for other purposes expressly permitted by the GDPR).
•     Data subjects are kept informed at all times of the purpose or purposes for which 
the Company uses their personal data. Please refer to Part 12 for more information on keeping data 
subjects informed.

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6.    Adequate, Relevant, and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the 
specific purpose or purposes of which data subjects have been informed (or will be informed) as 
under Part 5, above, and as set out in Part 21, below.

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7.    Accuracy of Data and Keeping Data Up-to-Date

•     The Company shall ensure that all personal data collected, processed, and held by it 
is kept accurate and up-to-date. This includes, but is not limited to, the rectification of 
personal data at the request of a data subject, as set out in Part 14, below.
•     The accuracy of personal data shall be checked when it is collected and at regular 
intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable 
steps will be taken without delay to amend or erase that data, as appropriate.

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8.    Data Retention

•     The Company shall not keep personal data for any longer than is necessary in light 
of the purpose or purposes for which that personal data was originally collected, held, and 
processed.

•     When personal data is no longer required, all reasonable steps will be taken to 
erase or otherwise dispose of it without delay.
•     For full details of the Company’s approach to data retention, including retention 
periods for specific personal data types held by the Company, please refer to our Data Retention 
Policy.

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9.    Secure Processing

The Company shall ensure that all personal data collected, held, and processed is kept secure and 
protected against unauthorised or unlawful processing and against accidental loss, destruction, or 
damage. Further details of the technical and organisational measures which shall be taken are 
provided in Parts 22 to 27 of this Policy.

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10.  Accountability and Record-Keeping

•     The Company’s Data Protection Officer is Mark Peberdy, 3000 Academy Park, Glasgow, 
G51 1PR. mark@comharra.com.
•     The Data Protection Officer shall be responsible for overseeing the implementation 
of this Policy and for monitoring compliance with this Policy, the Company’s other data 
protection-related policies, and with the GDPR and other applicable data protection legislation.
•     The Company shall keep written internal records of all personal data collection, 
holding, and processing, which shall incorporate the following information:
•     The name and details of the Company, its Data Protection Officer, and any applicable 
third- party data processors;
•     The purposes for which the Company collects, holds, and processes personal data;
•     Details of the categories of personal data collected, held, and processed by the 
Company, and the categories of data subject to which that personal data relates;
•     Details of any transfers of personal data to non-EEA countries including all 
mechanisms and security safeguards;
•     Details of how long personal data will be retained by the Company (please refer to 
the Company’s Data Retention Policy); and

•     Detailed descriptions of all technical and organisational measures taken by the 
Company to ensure the security of personal data.

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11.   Data Protection Impact Assessments

•     The Company 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 GDPR.
•     Data Protection Impact Assessments shall be overseen by the Data Protection Officer 
and shall address the following:
•     The type(s) of personal data that will be collected, held, and processed;
•     The purpose(s) for which personal data is to be used;
•     The Company’s objectives;
•     How personal data is to be used;
•     The parties (internal and/or external) who are to be consulted;
•     The necessity and proportionality of the data processing with respect to the 
purpose(s) for which it is being processed;
•     Risks posed to data subjects;
•     Risks posed both within and to the Company; and
•     Proposed measures to minimise and handle identified risks.

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12.  Keeping Data Subjects Informed

The Company shall provide the information set out in Part 12.2 to every data subject:
•     Where personal data is collected directly from data subjects, those data subjects 
will be informed of its purpose at the time of collection; and
•     Where personal data is obtained from a third party, the relevant data subjects will 
be informed of its purpose:
1.    if the personal data is used to communicate with the data subject, when the first 
communication is made; or
2.    if the personal data is to be transferred to another party, before that transfer is made; or
3.    as soon as reasonably possible and in any event not more than one month after the

personal data is obtained.

•     The following information shall be provided:
•     Details of the Company including, but not limited to, the identity of its Data 
Protection Officer;
•     The purpose(s) for which the personal data is being collected and will be processed 
(as detailed in Part 21 of this Policy) and the legal basis justifying that collection and 
processing;
•     Where applicable, the legitimate interests upon which the Company is justifying its 
collection and processing of the personal data;
•     Where the personal data is not obtained directly from the data subject, the 
categories of personal data collected and processed;
•     Where the personal data is to be transferred to one or more third parties, details 
of those parties;
•     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);
•     Details of data retention;
•     Details of the data subject’s rights under the GDPR;
•     Details of the data subject’s right to withdraw their consent to the Company’s 
processing
of their personal data at any time;
•     Details of the data subject’s right to complain to the Information Commissioner’s 
Office (the “supervisory authority” under the GDPR);
•     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; and
•     Details of any automated decision-making or profiling that will take place using the 
personal data, including information on how decisions will be made, the significance of those 
decisions, and any consequences.

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13.  Data Subject Access
•     Data subjects may make subject access requests (“SARs”) at any time to find out more 
about the personal data which the Company holds about them, what it is doing with that personal 
data, and why.

•     Employees wishing to make a SAR should do using a Subject Access Request Form, 
sending the form to the Company’s Data Protection Officer at 3000 Academy Park, Glasgow, G51 1PR or 
mark@comharra.com.
•     Responses to SARs shall normally be made within one month of receipt, however this 
may be extended by up to two months if the SAR is complex and/or numerous requests are made. If 
such additional time is required, the data subject shall be informed.
•     All SARs received shall be handled by the Company’s Data Protection Officer.
•     The Company does not charge a fee for the handling of normal SARs. The Company 
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.

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14.  Rectification of Personal Data
•     Data subjects have the right to require the Company to rectify any of their personal 
data that is inaccurate or incomplete.
•     The Company shall rectify the personal data in question, and inform the data subject 
of that rectification, within one month of the data subject informing the Company of the issue. The 
period can be extended by up to two months in the case of complex requests. If such additional time 
is required, the data subject shall be informed.
•     In the event that any affected personal data has been disclosed to third parties, 
those parties shall be informed of any rectification that must be made to that personal data.

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15.  Erasure of Personal Data

•     Data subjects have the right to request that the Company erases the personal data it 
holds about them in the following circumstances:
•     It is no longer necessary for the Company to hold that personal data with respect to 
the purpose(s) for which it was originally collected or processed;
•     The data subject wishes to withdraw their consent to the Company holding and 
processing their personal data;

•     The data subject objects to the Company holding and processing their personal data 
(and there is no overriding legitimate interest to allow the Company to continue doing so) (see 
Part 18 of this Policy for further details concerning the right to object);
•     The personal data has been processed unlawfully;
•     The personal data needs to be erased in order for the Company to comply with a 
particular legal obligation
•     Unless the Company 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. The period can be extended by up to two months 
in the case of complex requests. If such additional time is required, the data subject shall be 
informed.
•     In the event that any personal data that is to be erased in response to a data 
subject’s 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).

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16.  Restriction of Personal Data Processing

•     Data subjects may request that the Company ceases processing the personal data it 
holds about them. If a data subject makes such a request, the Company shall retain only the amount 
of personal data concerning that data subject (if any) that is necessary to ensure that the 
personal data in question is not processed further.
•     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).

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17.  Data Portability

•     The Company processes personal data using automated means such as via software 
systems, email and other electronic methods.
•     Where data subjects have given their consent to the Company to process their 
personal data in such a manner, or the processing is otherwise required for the performance of a 
contract between the Company and the data subject, data subjects have the right, under

the GDPR, to receive a copy of their personal data and to use it for other purposes (namely 
transmitting it to other data controllers).
•     To facilitate the right of data portability, the Company shall make available all 
applicable personal data to data subjects in the following formats:
•     In writing or by email
•     Where technically feasible, if requested by a data subject, personal data shall be 
sent directly to the required data controller.
•     All requests for copies of personal data shall be complied with within one month of 
the data subject’s request. The period can be extended by up to two months in the case of complex 
or numerous requests. If such additional time is required, the data subject shall be informed.

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18.  Objections to Personal Data Processing
•     Data subjects have the right to object to the Company processing their personal data 
based on legitimate interests, direct marketing (including profiling).
•     Where a data subject objects to the Company processing their personal data based on 
its legitimate interests, the Company shall cease such processing immediately, unless it can be 
demonstrated that the Company’s legitimate grounds for such processing override the data subject’s 
interests, rights, and freedoms, or that the processing is necessary for the conduct of legal 
claims.
•     Where a data subject objects to the Company processing their personal data for 
direct marketing purposes, the Company shall cease such processing immediately.

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19.  Automated Decision-Making
•     The Company uses personal data in automated decision-making processes for 
referencing
•     Where such decisions have a legal (or similarly significant effect) on data 
subjects, those data subjects have the right to challenge to such decisions under the GDPR, 
requesting human intervention, expressing their own point of view, and obtaining an explanation of 
the decision from the Company.
•     The right described in Part 19.2 does not apply in the following circumstances:

•     The decision is necessary for the entry into, or performance of, a contract between 
the Company and the data subject;
•     The decision is authorised by law; or
•     The data subject has given their explicit consent.

20. Profiling

The Company does not use personal data for profiling purposes.

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21.  Personal Data Collected, Held, and Processed

The following personal data is collected, held, and processed by the Company (for details of data
retention, please refer to the Company’s Data Retention Policy):

21.1 Data we collect:
•     Name,
•     Business Address,
•     Email addresses,
•     Telephone numbers

The above data is collected, held and processed for the purpose of conducting our day to day 
business:

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22.  Data Security – Transferring Personal Data and Communications

The Company shall ensure that the following measures are taken with respect to all
communications and other transfers involving personal data:
•     All emails containing personal data must be transferred over secure network.
•     Personal data may be transmitted over secure networks only; transmission over 
unsecured networks is not permitted in any circumstances;
•     Personal data may not be transmitted over a wireless network if there is a wired 
alternative that is reasonably practicable;

•     Personal data contained in the body of an email, whether sent or received, should be 
copied from the body of that email and stored securely. The email itself should be permanently 
deleted;
•     Where personal data is to be transferred in hardcopy form it should be passed 
directly to the recipient.

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23.  Data Security – Storage

The Company shall ensure that the following measures are taken with respect to the storage of 
personal data:
•     All electronic copies of personal data are stored securely on the company server;
•     All hardcopies of personal data are stored securely in a locked cabinet;
•     All personal data stored electronically is backed up overnight.
•     No personal data is stored on any mobile device (including, but not limited to, 
laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without 
the formal written approval of the Managing Director and in the event of such approval, strictly in 
accordance with all instructions and limitations described at the time the approval is given, and 
for no longer than is absolutely necessary;
•     No personal data is 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 the Company where the party in question has agreed to comply fully 
with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to the 
Company that all suitable technical and organisational measures have been taken).

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24. Data Security – Disposal

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 is securely deleted and disposed of. For 
further information on the deletion and disposal of personal data, please refer to the Company’s 
Data Retention Policy.

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25. Data Security – Use of Personal Data

The Company shall ensure that the following measures are taken with respect to the use of personal 
data:
•     No personal data may be shared informally and if an employee, agent, sub-contractor, 
or other party working on behalf of the Company requires access to any personal data that they do 
not already have access to, such access should be formally requested from the Data Protection 
Officer.
•     No personal data may be transferred to any employees, agents, contractors, or other 
parties, whether such parties are working on behalf of the Company or not, without the 
authorisation of the Data Protection Officer.
•     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;
•     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;
•     Where personal data held by the Company is used for marketing purposes, it shall be 
the responsibility of the Company’s administrator 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.

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26. Data Security – IT Security

The Company shall ensure that the following measures are taken with respect to IT and information 
security:
•     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. All software used 
by the Company is designed to require such passwords;
•     Under no circumstances should any passwords be written down or shared between any 
employees, agents, contractors, or other parties working on behalf of the Company, 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;

•     All software (including, but not limited to, applications and operating systems) 
shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all 
security-related updates as soon as reasonably and practically possible.
•     No software may be installed on any Company-owned computer or device without the 
prior approval of the Senior Management.

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27.  Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, 
holding, and processing of personal data:
•     All employees, agents, contractors, or other parties working on behalf of the 
Company shall be made fully aware of both their individual responsibilities and the Company’s 
responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this 
Policy;
•     Only employees, agents, sub-contractors, or other parties working on behalf of the 
Company 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 the Company;
•     All employees, agents, contractors, or other parties working on behalf of the 
Company handling personal data will be appropriately trained to do so;
•     All employees, agents, contractors, or other parties working on behalf of the 
Company handling personal data will be appropriately supervised;
•     All employees, agents, contractors, or other parties working on behalf of the 
Company handling personal data shall be required and encouraged to exercise care, caution, and 
discretion when discussing work-related matters that relate to personal data, whether in the 
workplace or otherwise;
•     Methods of collecting, holding, and processing personal data shall be regularly 
evaluated and reviewed;
•     All personal data held by the Company shall be reviewed periodically, as set out in 
the Company’s Data Retention Policy;
•     The performance of those employees, agents, contractors, or other parties working on 
behalf of the Company handling personal data shall be regularly evaluated and reviewed;
•     All employees, agents, contractors, or other parties working on behalf of the 
Company handling personal data will be bound to do so in accordance with the principles of the
GDPR and this Policy by contract;                                                     

•     All agents, contractors, or other parties working on behalf of the Company 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 the Company arising 
out of this Policy and the GDPR; and
•     Where any agent, contractor or other party working on behalf of the Company handling 
personal data fails in their obligations under this Policy that party shall indemnify and hold 
harmless the Company against any costs, liability, damages, loss, claims or proceedings which may 
arise out of that failure.

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28. Transferring Personal Data to a Country Outside the EEA

•     The Company may from time to time transfer (‘transfer’ includes making available 
remotely)
personal data to countries outside of the EEA.
•     The transfer of personal data to a country outside of the EEA shall take place only 
if one or more of the following applies:
•     The transfer is to a country, territory, or one or more specific sectors in that 
country (or an international organisation), that the European Commission has determined ensures an 
adequate level of protection for personal data;
•     The transfer is to a country (or international organisation) which provides 
appropriate safeguards in the form of a legally binding agreement between public authorities or 
bodies; binding corporate rules; standard data protection clauses adopted by the European 
Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. 
the Information Commissioner’s Office); certification under an approved certification mechanism (as 
provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory 
authority; or provisions inserted into administrative arrangements between public authorities or 
bodies authorised by the competent supervisory authority;
•     The transfer is made with the informed consent of the relevant data subject(s);
•     The transfer is necessary for the performance of a contract between the data subject 
and the Company (or for pre-contractual steps taken at the request of the data subject);
•     The transfer is necessary for important public interest reasons;
•     The transfer is necessary for the conduct of legal claims;

•     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
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.

29.  Data Breach Notification

•     All personal data breaches must be reported immediately to the Company’s Data
Protection Officer.
•     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, and in any event, within 72 hours after having become aware of it.
•     In the event that a personal data breach is likely to result in a high risk (that 
is, a higher risk than that described under Part 29.2) 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.
•     Data breach notifications shall include the following information:
•     The categories and approximate number of data subjects concerned;
•     The categories and approximate number of personal data records concerned;
•     The name and contact details of the Company’s data protection officer (or other 
contact point where more information can be obtained);
•     The likely consequences of the breach;
•     Details of the measures taken, or proposed to be taken, by the Company to address 
the breach including, where appropriate, measures to mitigate its possible adverse effects.

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30. Implementation of Policy

This Policy shall be deemed effective as of 04th  July 2020. No part of this Policy shall have 
retroactive effect and shall thus apply only to matters occurring on or after this date. 

31.  Complaints

If you feel that your data has not been handled correctly, or you are unhappy with our response to 
any requests you have made to us regarding the use of your personal data, you have the right to 
lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113 or go online to