Data Protection Policy
1. Data protection principles
The Supplier is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
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 they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must 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;
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 are 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 individuals; and
f. 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.”
2. General provisions
a. This policy applies to all personal data processed by the Supplier.
b. The Responsible Person shall take responsibility for the Supplier’s ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.
d. The Supplier shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, the Supplier shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to the Supplier shall be dealt with in a timely manner.
4. Lawful purposes
a. All data processed by the Supplier must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
b. The Supplier shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt in consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Supplier’s systems.
5. Data minimisation
a. The Supplier shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
b. All data that the Supplier receives shall unequivocally be used for the sole purpose of giving the Client better product recommendations & AI-generated personalization. Both the data and the models that are trained on the data must only be used for the specific client from which the data was obtained.
a. The Supplier shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
7. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, the Supplier shall put in place an archiving policy for each area in which personal data is processed and review this process annually.