Data Protection Policy

Data Protection

Tilsun Group

The Tilsun Group is committed to compliance under GDPR law, this includes building GDPR into current and future contractual commitments.

Data Protection Principles

The Company 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.

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 it is 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 are processed; 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.”

General Provisions

" a) This policy applies to all personal data processed by the Company.

b) The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.

c) This policy shall be reviewed at least annually or where there is a significant change to process

d) The Company shall register with the Information Commissioner’s Office as an organisation that processes personal data.

Lawful, fair and transparent processing

a) Processes shall be reviewed at least annually or where there has been a significant change to process

b) Individuals have the right to access their personal data, and any such requests made to the Company shall be dealt with in a timely manner compliant with GDPR requirements.

Lawful purposes

a) All data processed by the company must be done on one of the following lawful bases: consent, contract, legal obligation, or legitimate interests (see ICO guidance for more information).

b) Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

c) 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 Company’s systems.

Data minimisation

The Company shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

Accuracy

a) The Company 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.

Archiving & removal

a) To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually or when there has been a significant change to process

b) The archiving policy shall consider what data should/must be retained, for how long, and why.

Security

a) The Company shall ensure that personal data is stored securely using modern software that is kept-up-to-date.

b) Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.

c) When personal data is deleted this should be done safely such that the data is irrecoverable.

d) Appropriate back-up and disaster recovery solutions shall be in place.

Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the organisation shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO in accordance with GDPR requirements (i.e. within 72 hours of identification of the incident to the ICO and without unreasonable delay to the affected data subject(s)) (more information on the ICO website).

Definitions

Company: Tilsun Group GDPR: General Data Protection Regulation Responsible Person: Adele Pointon / David Snarr