TERMS & CONDITIONS
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Our website www.raydodd.co.uk (“Our Site”) is operated by Ray Dodd Limited, a limited company incorporated and registered in England and Wales with company number 11080799, whose registered office is at 3 Preston Place, Chapel Street, Faversham, Kent, United Kingdom, ME13 8ER.
Our Site uses cookies to distinguish you from other users of Our Site. This helps us to provide you with a good experience when you browse Our Site and also allows us to improve Our Site. By continuing to browse Our Site, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of Our Site. They include, for example, cookies that enable you to log into secure areas of Our Site, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around Our Site when they are using it. This helps us to improve the way Our Site works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to Our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to Our Site, the pages you have visited and the links you have followed. We will use this information to make Our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Cookie Name Purpose Duration
Advertising _privy_8A0E31E586514FA49B4B9259 The purpose of this cookie is to determine who we should display advertising campaigns to.
Two (2) months
Advertising _privy_AAC43C4B575CCAC7B44A5AC2 The purpose of this cookie is to determine who we should display advertising campaigns to.
One (1) year
Advertising _privy_a The purpose of this cookie is to determine who we should display advertising campaigns to.
Ten (10) years
Advertising _privy_b The purpose of this cookie is to determine who we should display advertising campaigns to.
One (1) day
Advertising _privy_match_session The purpose of this cookie is to determine who we should display advertising campaigns to.
One (1) week
Advertising _privy_undefined The purpose of this cookie is to determine who we should display advertising campaigns to.
Two (2) months
Affiliates IR_PI The purpose of this cookie is to track affiliate driven users.
Six (6) years
Affiliates IR_gbd The purpose of this cookie is to track affiliate driven users.
Six (6) years
Cloudflare __cfduid The purpose of this cookie is to identify individual visitors who may be using a shared IP address in order to apply relevant security settings.
Five (5) years
Google Analytics __utma The purpose of this cookie is to provide information about the number of unique visitors to the website.
Two (2) years
Google Analytics __zlcmid The purpose of this cookie is to provide information about the number of unique visitors to the website.
One (1) year
Google Analytics _ga The purpose of this cookie is to track users within Google Analytics to anaylse trends in website usage.
Two (2) years
Google Analytics _gid The purpose of this cookie is to track users within Google Analytics to anaylse trends in website usage.
One (1) day
Functional Crumb
This purpose of this cookie is to prevent an attack known as cross-site request forgery (CSRF).
Length of session
Optimisation optimizelyBuckets The purpose of this cookie is to store visitor preferences.
Ten (10) years
Optimisation optimizelyEndUserId The purpose of this cookie is to identify unique visitors to the website.
Ten (10) years
Optimisation optimizelySegments The purpose of this cookie is to store visitor preferences relating to appearance of the site.
Ten (10) years
ShareThis __sharethis_cookie_test__ The purpose of this cookie is to monitor click-stream activity (i.e. pages views, navigation from page to page, etc).
Two (2) years
Squarespace SS_ABPP The purpose of this cookie is to provide information about device and browser usage.
Three (3) years
Squarespace SS_MATTR The purpose of this cookie is to provide information about device and browser usage.
Nine (9) years
Squarespace SS_MID The purpose of this cookie is to provide information about device and browser usage.
Eight (8) years
Squarespace ss_cid The purpose of this cookie is to identify unique visitors and track a visitor’s sessions on a website.
Two (2) years
Squarespace ss_cpvisit The purpose of this cookie is to identify unique visitors and track a visitor’s sessions on a website.
Two (2) years
Squarespace ss_cvisit The purpose of this cookie is to identify unique visitors and track a visitor’s sessions on a website.
30 minutes
Squarespace ss_cvr The purpose of this cookie is to identify unique visitors and track a visitor’s sessions on a website.
Two (2) years
Squarespace ss_cvt The purpose of this cookie is to identify unique visitors and track a visitor’s sessions on a website.
30 minutes
Targeting / Advertising 1P_JAR The purpose of this cookie is to identify how the visitor uses the website and any advertising the visitor may have seen.
Two (2) weeks
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of Our Site.
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1. ABOUT THIS POLICY
The corporate information, records and data of Ray Dodd Limited is important to how we conduct business and manage employees.
There are legal and regulatory requirements for us to retain certain data, usually for a specified amount of time. We also retain data to help our business operate and to have information available when we need it. However, we do not need to retain all data indefinitely, and retaining data can expose us to risk as well as be a cost to our business.
This Data Protection Policy explains our requirements to retain data and to dispose of data and provides guidance on appropriate data handling and disposal. Failure to comply with this policy can expose us to fines and penalties, adverse publicity, difficulties in providing evidence when we need it and in running our business.
This policy does not form part of any employee's contract of employment and we may amend it at any time.
2. INTERPRETATION
2.1. DEFINITIONS:
Company: Ray Dodd Limited, a limited company incorporated and registered in England and Wales with company number 11080799, whose registered office is at 3 Preston Place, Chapel Street, Faversham, Kent, United Kingdom, ME13 8ER.
Company Personnel: all employees, workers, contractors, agency workers, consultants, directors, members and others.
Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear positive action, signify agreement to the Processing of Personal Data relating to them.
Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.
Criminal Convictions Data: means personal data relating to criminal convictions and offences and includes personal data relating to criminal allegations and proceedings.
Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.
Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA should be conducted for all major system or business change programmes involving the Processing of Personal Data.
Data Protection Officer (DPO): the person required to be appointed in specific circumstances under the GDPR. Where a mandatory DPO has not been appointed, this term means a data protection manager or other voluntary appointment of a DPO or refers to the Company data privacy team with responsibility for data protection compliance.
EEA: the 28 countries in the EU, and Iceland, Liechtenstein and Norway.
Explicit Consent: consent which requires a very clear and specific statement (that is, not just action).
General Data Protection Regulation (GDPR): the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the GDPR.
Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal Data specifically includes, but is not limited to, identity data, contact data, transaction data, profile data, and marketing and communications data.
Personal Data Breach: 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 our 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.
Privacy Guidelines: the Company privacy and GDPR related guidelines provided to assist in interpreting and implementing this Data Protection Policy and Related Policies, available on request.
Privacy Policies: separate notices setting out information that may be provided to Data Subjects when the Company collects information about them. These policies may take the form of general privacy statements applicable to a specific group of individuals (for example, the website privacy policy) or they may be stand-alone, one-time privacy statements covering Processing related to a specific purpose.
Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.
Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.
Related Policies: the Company’s policies, operating procedures or processes related to this Data Protection Policy and designed to protect Personal Data, available on request.
Special Categories of Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.
3. INTRODUCTION
This Data Protection Policy sets out how the Company (”we”, “our”, “us”, “the Company”) handle the Personal Data of our customers, suppliers, employees, workers and other third parties.
This Data Protection Policy applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject.
This Data Protection Policy applies to all Company Personnel (”you”, “your”). You must read, understand and comply with this Data Protection Policy when Processing Personal Data on our behalf and attend training on its requirements. This Data Protection Policy sets out what we expect from you for the Company to comply with applicable law. Your compliance with this Data Protection Policy is mandatory. Related Policies and Privacy Guidelines are available to help you interpret and act in accordance with this Data Protection Policy. You must also comply with all such Related Policies and Privacy Guidelines. Any breach of this Data Protection Policy may result in disciplinary action.
Where you have a specific responsibility in connection with Processing such as capturing Consent, reporting a Personal Data Breach, conducting a DPIA as referenced in this Data Protection Policy or otherwise then you must comply with the Related Policies and Privacy Guidelines.
This Data Protection Policy (together with Related Policies and Privacy Guidelines) is an internal document and cannot be shared with third parties, clients or regulators without prior authorisation from the DPO.
4. SCOPE
We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times.
The DPO is responsible for overseeing this Data Protection Policy and, as applicable, developing Related Policies and Privacy Guidelines. That post is held by Ray Dodd.
Please contact the DPO with any questions about the operation of this Data Protection Policy or the GDPR or if you have any concerns that this Data Protection Policy is not being or has not been followed.
5. LAWFULNESS, FAIRNESS, TRANSPARENCY
Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject.
You may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing, but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.
The GDPR allows Processing for specific purposes, some of which are set out below:
a) the Data Subject has given his or her Consent;
b) the Processing is necessary for the performance of a contract with the Data Subject;
c) to meet our legal compliance obligations;
d) to protect the Data Subject’s vital interests;
e) to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Policies.
You must identify and document the legal ground being relied on for each Processing activity.
6. CONSENT
A Controller must only process Personal Data on the basis of one or more of the lawful bases set out in the GDPR, which include Consent.
A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters.
Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured. Consent may need to be refreshed if you intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented.
When processing Special Category Data or Criminal Convictions Data, we will usually rely on a legal basis for processing other than Explicit Consent or Consent if possible. Where Explicit Consent is relied on, you must issue a Privacy Policy to the Data Subject to capture Explicit Consent.
You will need to evidence Consent captured and keep records of all Consents in accordance with Related Policies and Privacy Guidelines so that the Company can demonstrate compliance with Consent requirements.
7. TRANSPARENCY – NOTIFYING DATA SUBJECTS
The GDPR requires Data Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. The information must be provided through appropriate Privacy Policies which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them.
Whenever we collect Personal Data directly from Data Subjects, including for human resources or employment purposes, we must provide the Data Subject with all the information required by the GDPR including the identity of the Controller and DPO, how and why we will use, Process, disclose, protect and retain that Personal Data through a Privacy Policy which must be presented when the Data Subject first provides the Personal Data.
When Personal Data is collected indirectly (for example, from a third party or publicly available source), we must provide the Data Subject with all the information required by the GDPR as soon as possible after collecting or receiving the data. We must also check that the Personal Data was collected by the third party in accordance with the GDPR and on a basis which contemplates our proposed Processing of that Personal Data.
If you are collecting Personal Data from Data Subjects, directly or indirectly, then you must provide Data Subjects with a Privacy Policy in accordance with our Related Policies and Privacy Guidelines.
You must comply with the Company’s guidelines on drafting Privacy Policies.
8. PURPOSE LIMITATION
Personal Data must be collected only for specified, explicit and legitimate purposes. It must not be further Processed in any manner incompatible with those purposes.
You cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes and they have Consented where necessary.
9. DATA MINIMISATION
Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.
You may only Process Personal Data when performing your job duties requires it. You cannot Process Personal Data for any reason unrelated to your job duties.
You may only collect Personal Data that you require for your job duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes.
You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company’s data retention guidelines.
10. ACCURACY
Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.
You will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.
11. STORAGE LIMITATION
Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.
The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires that data to be kept for a minimum time.
You must not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.
You will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all the Company’s applicable records retention schedules and policies. This includes requiring third parties to delete that data where applicable.
You will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Policy.
Retention Periods
The Company establishes retention or destruction schedules or procedures for specific categories of data. This is done to ensure legal compliance with our data protection obligations and accomplish other objectives, such as protecting intellectual property and controlling costs.
If any of the following issues arise, please contact the DPO as a matter of urgency:
a) if you are unable to comply, or believe there is a valid reason for non-compliance,
b) if you hold data not listed in the table below;
c) if you become aware of any changes that may affect the periods listed in the table below;
d) if you have any other questions about the retention periods set out in the table below.
Type of Data Retention Period Reason / Comments
Identity data of clients Five (5) years from the end of the contract
Reasonable period to allow for re-engagement of services
Contact data of clients Five (5) years from the end of the contract
Reasonable period to allow for re-engagement of services
Transaction data of clients Six (6) years from the date of the transaction
Legal obligation to retain taxation records
Profile data of clients Five (5) years from the end of the contract; indefinitely as anonymised data
Reasonable period to allow for re-engagement of services
Marketing and communication data of clients Five (5) years from the end of communication
Reasonable period to allow for re-engagement of services
Identity data of contractors Seven (7) years from the end of the contract
Legal obligation to retain records relating to employment
Contact data of contractors Seven (7) years from the end of the contract
Legal obligation to retain records relating to employment
Transaction data of contractors Six (6) years from the date of the transaction
Legal obligation to retain taxation records
Profile data of contractors Five (5) years from the end of the contract
Reasonable period to allow for re-engagement of services
Marketing and communication data of contractors Five (5) years from the end of communication
Reasonable period to allow for re-engagement of services
12. SECURITY INTEGRITY AND CONFIDENTIALITY – PROTECTING PERSONAL DATA
Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.
We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data.
You agree to follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.
You agree to comply with and not attempt to circumvent the administrative, physical and technical safeguards we implement and maintain in accordance with the GDPR and relevant standards to protect Personal Data.
13. REPORTING A PERSONAL DATA BREACH
The GDPR requires Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data Subject.
We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.
If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the person or team designated as the key point of contact for Personal Data Breaches the DPO. You should preserve all evidence relating to the potential Personal Data Breach.
14. TRANSFER LIMITATION
The GDPR restricts data transfers to countries outside the EEA to ensure that the level of data protection afforded to individuals by the GDPR is not undermined.
You may only transfer Personal Data outside the EEA if one of the following conditions applies:
a) the European Commission has issued a decision confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subject’s rights and freedoms;
b) appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by the European Commission, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the DPO;
c) the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or
d) the transfer is necessary for one of the other reasons set out in the GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest.
15. DATA SUBJECT’S RIGHTS AND REQUESTS
Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:
a) withdraw Consent to Processing at any time;
b) receive certain information about the Data Controller’s Processing activities;
c) request access to their Personal Data that we hold;
d) prevent our use of their Personal Data for direct marketing purposes;
e) ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;
f) restrict Processing in specific circumstances;
g) challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;
h) request a copy of an agreement under which Personal Data is transferred outside of the EEA;
i) prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;
j) be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;
k) make a complaint to the supervisory authority;
l) in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine-readable format.
You must verify the identity of an individual requesting data under any of the rights listed above.
You must immediately forward any Data Subject request you receive to the DPO.
16. ACCOUNTABILITY
The Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.
The Company must have adequate resources and controls in place to ensure and to document GDPR compliance including:
a) appointing a suitably qualified DPO (where necessary) and an executive accountable for data privacy;
b) completing DPIAs where Processing presents a high risk to rights and freedoms of Data Subjects;
c) integrating data protection into internal documents including this Data Protection Policy, Related Policies, Privacy Guidelines or Privacy Policies;
d) regularly training Company Personnel on the GDPR, this Data Protection Policy, Related Policies and Privacy Guidelines and data protection matters including, for example, Data Subject’s rights, Consent, legal basis, DPIA and Personal Data Breaches. The Company must maintain a record of training attendance by Company Personnel; and
e) regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort.
17. RECORD KEEPING
The GDPR requires us to keep full and accurate records of all our data Processing activities.
You must keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects’ Consents and procedures for obtaining Consents.
These records should include, at a minimum, the name and contact details of the Controller and the DPO, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data’s retention period and a description of the security measures in place. To create the records, data maps should be created which should include the detail set out above together with appropriate data flows.
18. TRAINING AND AUDIT
We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.
You agree to undergo all mandatory data privacy related training and ensure your team undergo similar mandatory training.
You agree to regularly review all the systems and processes under your control to ensure they comply with this Data Protection Policy and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.
19. DATA PROTECTION IMPACT ASSESSMENT (DPIA)
Data controllers must conduct DPIAs in respect to high-risk Processing.
You should conduct a DPIA (and discuss your findings with the DPO) when implementing major system or business change programs involving the Processing of Personal Data including:
• use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes);
• large-scale Processing of Special Categories of Personal Data or Criminal Convictions Data; and
• large-scale, systematic monitoring of a publicly accessible area.
A DPIA must include:
• a description of the Processing, its purposes and the Data Controller’s legitimate interests if appropriate;
• an assessment of the necessity and proportionality of the Processing in relation to its purpose;
• an assessment of the risk to individuals; and
• the risk mitigation measures in place and demonstration of compliance.
20. DIRECT MARKETING
We are subject to certain rules and privacy laws when marketing to our customers.
For example, a Data Subject’s prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as “soft opt-in” allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.
The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information.
A Data Subject’s objection to direct marketing must be promptly honoured. If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.
21. SHARING PERSONAL DATA
Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.
You may only share the Personal Data we hold with another employee, agent or representative of our Company if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions.
You may only share the Personal Data we hold with third parties, such as our service providers, if:
a) they have a need to know the information for the purposes of providing the contracted services;
b) sharing the Personal Data complies with the Privacy Policy provided to the Data Subject and, if required, the Data Subject’s Consent has been obtained;
c) the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
d) the transfer complies with any applicable cross-border transfer restrictions; and
e) a fully executed written contract that contains GDPR-approved third party clauses has been obtained.
22. CHANGES TO THIS DATA PROTECTION POLICY
We keep this Data Protection Policy under regular review. This version was last updated in February 2019.
This Data Protection Policy does not override any applicable national data privacy laws and regulations in countries where the Company operates.