Data protection policy

1 Introduction

This Policy sets out the obligations of CCgroup (‘the Company”) regarding data protection and the rights of customers and suppliers (“data subjects”) in respect of their personal data under the General Data Protection Regulation (“the Regulation”).

The Regulation defines “personal data” as any information relating to any 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 out the procedures that are to be fo lowed when dealing wi h 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 a’ms to ensure compliance with the Regulation. The Regulation sets out the fol owing principles with which any party handling personal data must comply. All personal data must be:

a) processed lawfully, fairly, and in a transparent manner in relation to the data subject;

b) 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;

c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;

d) 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;

e) 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 CCgroup insight-driven tech PR Regulation in order to safeguard the rights and freedoms of the data subject;

f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against acc’ dental loss, destruction or damage, using appropriate technical or organisational measures.

3. Lawful, Fair, and Transparent Data Processing

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:

a) the data subject has given consent to the processing of his or her personal data for one or more
specific purposes;

b) 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;

c) processing is necessary for compliance with a legal obligation to which the controller is subject;

d) processing is necessary to protect the vital interests of the data subject or of another natural person;

e) 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;

f) 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.

4. Processed for Specified, Explicit and Legitimate Purposes

4.1 The Company collects and processes the personal data set out in Part 21 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) and data received from third parties (for example, where we are providing services on behalf of a cleaner, waste
broker, Business Improvement company or facility management company).

4.2 The Company only processes personal data for the specific purposes set out in Part 21 of this Policy (or for other
purposes expressly permitted by the Regulation). The purposes for which we process personal data will be informed
to data subjects at the time that their personal data is collected, where it is collected directly from them, or as soon as
possible (not more than one calendar month) after collection where it is obtained from a third party.

5. 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(s)
informed to data subjects as under Part 4, above.

6. Accuracy of Data and Keeping Data Up To Date

The Company 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 regular 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.

7. Timely Processing

The Company 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.

8. Secure Processing

The Company 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 and 23 of this Policy.

9. Accountability

9.1 The Company’s Information Asset Owner is Giuseppina Popolo, (207-215 KingsCross Road, WC1X 9DN).

9.2 The Company shall keep written internal records of all personal data collection, holding, and processing, which shall
incorporate the following information:

a) The name and details of the Company, its data protection officer, and any applicable third party data controllers;

b) The purposes for which the Company processes personal data;

c) 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;

d) Details (and categories) of any third parties that will receive personal data from the Company;

e) Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;

f) Details of how long personal data will be retained by the Company; and

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

10. Privacy Impact Assessments

The Company shall carry out Privacy Impact Assessments when and as required under the Regulation. Privacy Impact
Assessments shall be overseen by the Company’s data protection officer and shall address the following areas of
importance:

10.1 The purpose(s) for which personal data is being processed and the processing operations to be carried out on
that data;

10.2 Details of the legitimate interests being pursued by the Company;

10.3 An assessment of the necessity and proportionality of the data processing with respect to the purposels) for which it
is being processed;

10.4 An assessment of the risks posed to individual data subjects; and

10.5 Details of the measures in place to minimise and handle risks including safeguards. data security. and other
measures and mechanisms to ensure the protection of personal data. sufficient to demonstrate compliance
with the Regulation.

24- Data Breach Notification

24.1 All personal data breaches must be reported immediately to the Company’s data protection officer.

24.2 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, and in any event. within 72 hours after having become aware of it.

24.3 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 25.2) 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.

24.4 Data breach notifications shall include the following information:

a) The categories and approximate number of data subjects concerned;

b) The categories and approximate number of personal data records concerned;

c) The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained];

d) The likely consequences of the breach;

e) 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.

25. Implementation of Policy

This Policy shall be deemed effective as of 25th May 2018. 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 and authorised by:

Name: Richard Fogg
Position: Chief Executive Officer
Date: 25th May 2018
Due for Review by: 25th May 2018

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