Everyone has rights as to how their Personal Data is managed. We will collect, store, and process Personal Data about our clients, suppliers, employees, and others (Data Subjects). We recognise that this Data's correct and lawful treatment will maintain confidence in Assist Protect Ltd. and ensure best practices in business operations.

Data users must comply with this policy when processing Personal Data on our behalf. Any breach of this policy may result in disciplinary action.

The types of Personal Data that Assist Protect Ltd. (we) may be required to manage may include information about current and past clients, suppliers, employees, and others we communicate with. Personal Data, which may be held on paper, computer, or other media, is subject to certain legal safeguards specified in the Data Protection Act 2018 (DPA), the General Data Protection Regulation 2018 (GDPR) and the Privacy and Electronic Communications Regulations 2003 (As Amended)(PECR).

This policy and any other documents referred to within set the basis on which we will process any Personal Data we collect from Data Subjects or provided to us by Data Subjects or other sources.

The Director has approved this policy of Assist Protect Ltd. It sets out rules for Data Protection and the legal conditions that must be satisfied when obtaining, handling, processing, transferring, and storing Personal Data.

This policy is not part of any employee's employment contract and may be amended.

The Data Protection Officer (DPO) ensures compliance with the Act, Directive, and Policy. Hebborn Consultancy Ltd holds the responsibility of DPO. Any questions concerning the compliance of this policy or the procedure that has not been followed should be referred in the first instance to the Data Protection Officer.

• Data is information stored electronically, such as a computer, mobile phone, CCTV images, or specific paper-based filing systems. This includes visitors' books.


• Data Subjects for this policy include all living individuals for whom we hold Personal Data. A Data Subject need not be a UK national or resident. All Data Subjects have legal rights concerning their personal information.


• Personal Data means Data relating to a natural living person who can be identified from that Data (or from that Data and other information in our possession). Personal Data can be factual (for example, a name, address, or date of birth) descriptive, or it can be an opinion about that person, their actions and behaviour.


• Data Controllers are the people or organisations that determine the purposes for and how Personal Data is processed. They are responsible for establishing practices and policies in line with the Act. For example, Assist Protect Ltd. is the Data Controller of all Personal Data used in our business for commercial purposes.


• Data Users include any employee or user within our organisation that processes Personal Data on our behalf and under our direct instructions. For the legislation and in this context, Data users act as the Data Controllers.


• Data Processors include any person or organisation who is not a Data Controller or user that processes Personal Data on our behalf and our instructions. Employees of Data Controllers are excluded from this definition, but it could include suppliers who manage Personal Data on Assist Protect Ltd's behalf.


• Processing is any activity that involves the use of Data. It includes obtaining, recording, or holding the Data, conducting any operation or set of processes on the Data, including organising, amending, retrieving, using, disclosing, erasing, or destroying it. Processing also includes transferring Personal Data to third parties.


• Special Category Data includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition, or sexual life, or about the commission of or proceedings for any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Special Category Data can only be processed under strict conditions, including requiring the person's express permission.

Anyone processing Personal Data must comply with the eight enforceable principles of good practice. These provide that Personal Data must be:

• processed fairly and lawfully
• processed for limited purposes and in an appropriate way
• adequate, relevant, and not excessive for the purpose
• accurate
• not kept longer than necessary for the purpose
• processed in line with Data Subjects' rights
• secure
• not transferred to people or organisations in countries without adequate protection.

The Act and Directive are not intended to prevent the processing of Personal Data but to ensure that it is done fairly and without adversely affecting the rights of the Data Subject.

For Personal Data to be processed lawfully, it must be processed based on one of the legal grounds set out in the Act and Directive. These include, among other things, the Data Subject's consent to the processing, or that the processing is necessary for the performance of a contract with the Data Subject, for the compliance with a legal obligation to which the Data Controller is subject, or for the legitimate interest of the Data Controller or the party to whom the Data is disclosed.V
When Special Category Data is being processed, additional conditions must be met. When processing Personal Data as Data Controllers during our business, we will ensure those requirements are met. (See our Appropriate Policy Document covering Special Category Data)

In the course of our business, we may collect and process the Personal Data set out in Schedule 1 of the DPA. This may include Data we receive directly from a Data Subject (for example, by completing forms or by corresponding with us by mail, phone, email or otherwise) and Data we receive from other sources (including, for example, business partners, sub-contractors in technical, payment and delivery services, credit reference agencies and others).

We will only process Personal Data for the specific purposes set out in Schedule 1 of the DPA or any other purposes expressly permitted by the Act and Directive. We will notify those purposes of the Data Subject when we first collect the Data or as soon as possible.

If we collect Personal Data directly from Data Subjects, we will inform them about the following:

• the purpose or purposes for which we intend to process that Personal Data
• the types of third parties, if any, with which we will share or to which we will disclose that Personal Data
• the means, if any, that Data Subjects can limit our use and disclosure of their Personal Data.

If we receive Personal Data about a Data Subject from other sources, we will provide the Data Subject with this information as soon as possible.

We will also inform Data Subjects whose Personal Data we process that we are the Data Controller concerning that Data and who the Data Protection Compliance Manager/Data Protection Officer is.

We will only collect Personal Data to the extent required for the specific purpose notified to the Data Subject.

We will ensure that our personal data is accurate and updated. We will check any personal data's accuracy at the point of collection and regular intervals afterwards. We will take all reasonable steps to amend, delete or destroy obsolete, outdated, or inaccurate Data.

We will only keep Personal Data as long as necessary for the purposes they were collected. We will take all reasonable steps to delete or destroy all Data no longer required from our systems.

We will process all Personal Data in line with a Data Subjects' rights, in particular, their:

• right to be informed
• right of access
• right to rectification
• right to erasure
• right to restrict processing
• right to data portability
• right to object
• rights concerning automated decision-making and profiling.

We will take appropriate security measures against unlawful or unauthorised processing of Personal Data and the accidental loss of, or damage to, Personal Data.

We have procedures and technologies to maintain the security of all Personal Data from the time of collection to the time of destruction. Personal Data will only be transferred to a Data Processor if they agree to comply with those procedures and policies or implement adequate measures. We will implement a Data Sharing Agreement where appropriate to assert our expectations of third-party compliance.

We maintain Data security by protecting the confidentiality, integrity, and availability of Personal Data, defined as follows:

• Confidentiality means that only people authorised to use the Data can access it.
• Integrity means that Personal Data should be accurate and suitable for the purpose for which it is processed.
• Availability means that authorised users should be able to access the Data if they need it for official purposes. Therefore, Personal Data should be stored on the Assist Protect Ltd. central computer system instead of individual PCs.

Security procedures include:

• Entry controls. Any stranger seen in entry-controlled areas must be challenged and reported
• Secure lockable desks and cupboards. Desks and cabinets must always be kept locked if they hold confidential information. (Personal information is always considered confidential.)
• Methods of disposal. Hard-copy documents should be shredded. Likewise, digital storage devices should be physically destroyed when they are no longer required,
• Equipment. Data users must ensure that others cannot see information displayed on their screen or workspace and that they lock/log off from their PC when left unattended.

We do not currently transfer any Personal Data we hold to countries outside of the United Kingdom (UK); however, if circumstances changed would only do so if one of the following conditions apply:

• the country to which the Personal Data is transferred ensures an adequate level of protection for the Data Subjects' rights and freedoms
• the Data Subject has given his consent
• the transfer is necessary for one of the reasons set out in the Act or Directive, including the performance of a contract between the Data Subject and us or to protect the Data Subject's vital interests
• the transfer is legally required on substantial public interest grounds or for the establishment, exercise, or defence of legal claims
• the relevant Data Protection Authority authorises the transfer
• we have adduced adequate safeguards concerning protecting the Data Subjects' privacy, their fundamental rights and freedoms, and the exercise of their rights.

Subject to the requirements in Clause 13.1 above, Personal Data we hold could also be processed by staff operating outside of the UK who work for one of our service providers or us. Those staff could be engaged in, among other things, the fulfilment of contracts with the Data Subject, the processing of payment details and the provision of support services.

We may disclose Personal Data we hold to third parties:

• if we sell or buy any business or assets, we may disclose the Personal Data we hold to the prospective seller or buyer of such business or assets
• if a third party acquires us or all our assets, the Personal Data we hold will be one of the transferred assets.

If we are under a duty to disclose or share a Data Subject's Data to comply with any legal obligation, to enforce or apply any contract with the Data Subject or other agreements, or to protect our rights, property, or the safety of our employees, customers, or others. This includes exchanging information for fraud protection and credit risk reduction with other companies and organisations.

We may also share Personal Data we hold with selected third parties for the purposes set out in Schedule 1 of the DPA 2018.

Data Subjects must formally request information we hold about them. This should be made in writing. Employees who receive a written request should forward it to their Line Manager or the Data Protection Officer immediately.

In the event of telephone or personal caller enquiries, we will only disclose Personal Data we hold on to our systems if the following conditions are met:

• We will check the caller's identity to ensure that information is only given to a person so entitled.
• We will require that the caller put their request in writing if we are unsure of the caller's identity or if their identity cannot be confirmed.

Our employees will refer a request to their Line Manager or the Data Protection Officer for assistance in challenging situations. However, our employees should not be intimidated into disclosing personal information.

In the event of a Data Breach, we have a procedure to minimise the impact of such a breach and contain and control the loss of Data.

Should a Data Breach occur or be suspected, it should be reported immediately and at the time of discovery to the Data Protection Compliance Manager/Data Protection Officer, who will implement the Data Breach Procedure, detailed in a separate Policy document.

We reserve the right to amend this policy at any time. We will notify Data Subjects of those amendments by mail or email.

Each time this document is amended/updated, the original document must be saved in its current form and archived accordingly. In addition, the details of the amendment are recorded on the amendment record.

Data Protection Policy 28th April 2023