Standard Terms And Conditions FOR THE PURCHASE OF GOODS

  1. Application

    1. The Buyer hereby orders and the Seller, by accepting the purchase order, agrees that it will supply the Goods specified overleaf upon and subject to these conditions which shall govern the Contract to the exclusion of any other terms and conditions. Any reference overleaf to the Seller’s quotation, specification, price list or like document shall be solely for the purpose of describing the Goods to be supplied and no terms and conditions endorsed upon, delivered with or referred to in such apply to the Contract.
  2. Interpretation

    1. In these Conditions:-

      “Address” means the address stated on the Order for delivery of the Goods;

      "Business Day" means any day other than a Saturday, Sunday or bank holiday;

      “Buyer” means Safeaid LLP a Limited Liability Partnership registered in England and Wales under number OC382751 whose registered office is at 16 Arnside Road, Waterlooville, Hampshire, PO7 7UP;

      “Conditions” means the standard terms and conditions of purchase set out in this document and (unless the context otherwise requires) includes any special terms and conditions agreed in writing between the Buyer and the Seller;

      “Contract” means the contract for the sale and purchase of the Goods constituted by the Seller’s acceptance of the Order in accordance with these Conditions;

      “Goods” means the goods (including any instalment of the goods or any part of them) described in the Order;

      “Order” means the Buyer’s purchase order to which these Conditions are annexed;

      “Price” means the price of the Goods;

      “Seller” means the person so described in the Order;

      “Specification” includes any plans, drawings, data or other information relating to the Goods;

      “Writing” includes via post, email and such other comparable means of communication.

    2. Any reference in these Conditions to a statute or a provision of a statute shall be construed as a reference to that statue or provision as amended, re-enacted or extended at the relevant time.
    3. The headings in these Conditions are for convenience only and shall not affect their interpretation.
  3. Basis Of purchase

    1. The Order constitutes an offer by the Buyer to purchase the Goods subject to these Conditions.
    2. Should the Seller choose to accept the Order placed by the Buyer, a binding contract for the supply of the Goods, subject to these conditions, shall exist by whichever is the earlier of: -
      1. the Seller’s acceptance of the Order, in writing or orally, subject to these conditions; or
      2. delivery of Goods.
    3. Any typographical clerical or other accidental error or omission in the Order placed by the Buyer or in any drawings specifications, instructions, tools or other material supplied by the Buyer, shall be subject to correction without any liability on the part of the Buyer.
    4. No variation to the Contract shall be binding unless agreed in writing between the authorised representatives of the Buyer and the Seller.
  4. Specification

    1. The quantity, quality and description of the Goods shall, subject as provided in these Conditions, be as specified in the Order and/or in any applicable Specification supplied by the Buyer to the Seller or agreed in writing by the Buyer.
    2. Any Specification supplied by the Buyer to the Seller, or specifically produced by the Seller for the Buyer, in connection with the Contract, together with the copyright, design rights or any other intellectual property rights in the Specification, shall be the exclusive property of the Buyer. The Seller shall not disclose to any third party or use any such Specification except to the extent that it is or becomes public knowledge through no fault of the Seller, or as required for the purpose of the Contract.
    3. The Goods shall be marked in accordance with the Buyer’s instructions and any applicable regulations or requirements of the carrier, and properly packed and secured so as to reach their destination in an undamaged condition in the ordinary course.
    4. The Seller shall comply with all applicable regulations or other legal requirements concerning the manufacture, packaging, packing and delivery of the Goods.
  5. Price

    1. The Price of the Goods shall be as stated in the Order and, unless otherwise so stated, shall be:-
      1. exclusive of any applicable value added tax (which shall be payable by the Buyer subject to receipt of a VAT invoices); and
      2. inclusive of all charges for packaging, packing, shipping, carriage, insurance and delivery of the Goods to the Address and any duties, imposts or levies other than value added tax.
    2. No increase in the Price may be made (whether on account of increased material, labour or transport costs, fluctuation in rates of exchange or otherwise) without the prior consent of the Buyer in writing.
  6. Payment

    1. The Seller shall be entitled to invoice the Buyer on or at any time after delivery of the Goods, as the case may be, and each invoice shall quote the number of the Order.
    2. Unless otherwise agreed with the Seller, the Buyer shall pay the Price of the Goods within 30 days after the end of the month of receipt by the Buyer of a proper invoice or, if later, after acceptance of the Goods in question by the Buyer, but time for payment shall not be of the essence of the contract.
    3. The Buyer shall be entitled to set off against the Price any sums owed to the Buyer by the Seller.
  7. Delivery

    1. The Goods shall be delivered to the Address on the date or within the period stated in the Order, in either case during the Buyer’s usual business hours.
    2. Where it is agreed in writing that the date of delivery of the Goods is to be specified by the Seller after the placing of the Order, the Seller shall give the Buyer reasonable notice in writing of the specified date.
    3. The time of delivery of the Goods is of the essence of the Contract.
    4. If the goods are to be delivered by instalments, the Contract will be treated as a single contract and not severable.
    5. The Buyer shall be entitled to reject any Goods delivered which are not in accordance with the Contract, and shall not be deemed to have accepted any Goods until the Buyer has had a reasonable time to inspect them following delivery.
    6. The Seller shall supply the Buyer in good time with any instructions or other information to enable the Buyer to accept delivery of the Goods.
    7. The Buyer shall not be obliged to return to the Seller any packaging or packing materials for the Goods, whether or not any Goods are accepted by the Buyer.
    8. The Buyer shall not be deemed to have accepted the Goods until it has had 5 days to inspect them following delivery or collection as the case may be. The Buyer shall also have the right to reject the Goods as though they had not been accepted for 5 days after any latent defect in the Goods has become apparent.
  8. Quality

    1. Where the Seller is not the manufacturer of the Goods, the Seller shall endeavor to transfer to the Buyer the benefit of any warranty or guarantee given to the Seller.
    2. The Seller warrants that (subject to the other provisions of these conditions) upon delivery the Goods shall:
      1. be of satisfactory quality within the meaning of the Sale of Goods Act 1979;
      2. be reasonably fit for purpose; and
      3. be reasonably fit for any particular purpose for which the Goods are being bought if the Buyer had made known that purpose to the Seller in writing and the Seller has confirmed in writing that it is reasonable for the Buyer to rely on the skill and judgment of the Seller.
    3. The Seller shall not be liable for a breach of any of the warranties in condition 8.2 unless:
      1. the Buyer gives written notice of the defect to the Seller, and, if the defect is as a result of damage in transit to the carrier, within 5 days of the time when the Buyer discovers the defect; and
      2. the Seller is given a reasonable opportunity after receiving the notice of examining such Goods and the Buyer (if asked to do so by the Seller) returns such Goods to the Seller’s place of business at the Seller’s cost for the examination to take place there.
    4. The Company shall not be liable for a breach of any of the warranties in condition 8.2 if:
      1. the Buyer makes any further use of such Goods after giving such notice; or
      2. the defect arises because the Buyer failed to follow the Seller’s oral or written instructions as to the storage, installation, commissioning, use or maintenance of the Goods or (if there are none) good trade practice.
    5. Subject to condition 8.3 and condition 8.4, if any of the Goods do not conform with any of the warranties in condition 8.2 the Seller shall at its option repair or replace such Goods (or the defective part) or refund the price of such Goods at the pro rata Contract rate provided that, if the Seller so requests, the Buyer shall, at the Seller’s expense, return the Goods or the part of such Goods which is defective to the Seller.
  9. Risk and Property

    1. Risk of damage to or loss of the Goods shall pass to the Buyer upon delivery to the Buyer in accordance with the Contract.
    2. The property in the Goods shall pass to the Buyer upon delivery, unless payment for the Goods has been agreed to be made prior to delivery, when it shall pass to the Buyer once payment has been made and the Goods have been appropriated to the Contract.
  10. Assignment

    1. The Buyer may assign the Contract or any part of it to any person, firm or company.
    2. The Seller shall not be entitled to assign the Contract or any part of it without the prior written consent of the Buyer.
  11. Warranty

    1. The Seller warrants to the Buyer that the Goods:-
      1. will, both at the time of delivery and for a reasonable period of time thereafter, conform in all respects with the Order and Specification supplied or advised by the Buyer to the Seller;
      2. will be free from defects in design, material and workmanship;
      3. will correspond with any relevant Specification or sample; and
      4. will comply with all statutory requirements and regulations relating to the sale of the Goods.
  12. Indemnity

    1. The Seller shall indemnify the Buyer in full against all liability, loss, damages, costs and expenses (including legal expenses) awarded against or incurred or paid by the Buyer as a result of or in connection with:-
      1. breach of any warranty given by the Seller in relation to the Goods;
      2. any claim that the Goods infringe, or that their importation, use or resale, infringes, the patent, copyright trademark or other intellectual property rights of any other person, except to the extent that the claim arises from compliance with any Specification supplied by the Buyer;
      3. any act or omission of the Seller or its employees, agents or sub-contractors in supplying, delivering or installing the Goods; and
      4. all claims by the customers of the Buyer (and their sub-buyers) arising out of any breach whatever by the Seller of this contract for sale.
  13. Remedies

    1. Without prejudice to any other right or remedy which the Buyer may have, if any Goods are not supplied in accordance with, or the Seller fails to comply with, any of the terms of the Contract the Buyer shall be entitled to avail itself of any one or more of the following remedies at its discretion, whether or not any part of the Goods have been accepted by the Buyer:
    2. to rescind the Order;
      1. to reject the Goods (in whole or in part) and return them to the Seller at the risk and cost of the Seller on the basis that a full refund for the Goods so returned shall be paid forthwith by the Seller;
      2. at the Buyer’s option to give the Seller the opportunity at the Seller's expense either to remedy any defect in the Goods or to supply replacement Goods and carry out any other necessary work to ensure that the terms of the Contract are fulfilled;
      3. to refuse to accept any further deliveries of the Goods but without any liability to the Seller;
      4. to carry out at the Seller's expense any work necessary to make the Goods comply with the Contract; and
      5. to claim such damages as may have been sustained in consequence of the Seller's breach or breaches of the Contract.
  14. Termination

    1. The Buyer shall be entitled to cancel the Contract in respect of all or part only of the Goods by giving notice in writing to the Seller at any time prior to delivery or performance, in which event the Buyer’s sole liability shall be to pay to the Seller the Price for the Goods in respect of which the Buyer has exercised its right of cancellation.
    2. The Buyer shall be entitled to terminate the Contract without liability to the Seller by giving notice to the Seller at any time if:-
      1. the Seller makes any voluntary arrangement with its creditors (within the meaning of the Insolvency Act 1986) or (being an individual or firm) becomes bankrupt or (being a company) becomes subject to an administration order or goes into liquidation (otherwise than for the purpose of amalgamation or reconstruction; or
      2. an encumbrancer takes possession, or a receiver is appointed, of any of the property or assets of the Seller; or
      3. the Seller ceases or threatens to cease, to carry on business; or
      4. the Buyer reasonably apprehends that any of the events mentioned above is about to occur in relation to the Seller and notifies the Seller accordingly.
  15. Force Majeure

    1. In the event that either party is prevented from fulfilling its obligations under this Agreement by reason of any supervening event beyond its control including but not limited to war, national emergency, flood, earthquake, strike or lockout the party shall not be deemed to be in breach of its obligations under this Agreement. The party shall immediately give notice of this to the other party and must take all reasonable steps to resume performance of its obligations.
    2. Each party shall be liable to pay to the other damages for any breach of this Agreement and all expenses and costs incurred by that party in enforcing its rights under this Agreement.
    3. If and when the period of such incapacity exceeds 3 months then this Agreement shall automatically terminate unless the parties first agree otherwise in writing.
  16. Communications

    1. All communications between the parties about the Contract shall be in writing and delivered by hand or sent by pre-paid first-class post or sent by electronic mail:
      1. (in case of communications to the Seller) to its registered office or such changed address as shall be notified to the Buyer by the Seller; or
      2. (in the case of the communications to the Buyer) to the registered office of the addressee (if it is a company) or (in any other case) to any address of the Seller set out in any document which forms part of the Contract or such other address as shall be notified to the Seller by the Buyer.
    2. Communications shall be deemed to have been received:
      1. if sent by pre-paid first-class post, two Business Days after posting (exclusive of the day of posting); or
      2. if delivered by hand, on the day of delivery; or
      3. if sent by electronic mail on a Business Day prior to 4.00 pm, at the time of transmission and otherwise on the next Business Day.
    3. Communications addressed to the Buyer shall be marked for the attention of Mr Barry Taylor.
    4. Any notice required or permitted to be given by either party to the other under these Conditions shall be in writing addressed to that other party at its registered office or principal place of business or such other address as may at the relevant time have been notified pursuant to this provision to the party giving the notice.
  17. Waiver

    1. No waiver by the Buyer of any breach of the Contract by the Seller shall be considered as a waiver of any subsequent breach of the same or any other provision.
    2. Severance
    3. If any provisions of these Conditions are held by any competent authority to be invalid or unenforceable in whole or in part the validity of the other provisions of these Conditions and the remainder of the provisions in question shall not be affected thereby.
    4. Third Party Rights
    5. A person who is not a party to the Contract shall have no rights under this Contract pursuant to the Contracts (Rights of Third Parties) Act 1999.
    6. Governing Law and Jurisdiction
    7. The Contract shall be governed by the laws of England and Wales and the parties agree to submit to the exclusive jurisdiction of the English and Welsh courts.

SAFEAID LLP GDPR POLICY

  1. Introduction

    This Policy sets out the obligations of Safeaid LLP ("Company") regarding data protection and the rights of its customers ("Data Subjects") in respect of their personal data under the General Data Protection Regulation ("Regulation").

    The Regulation defines "personal data" as any information relating to an 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 followed when dealing with personal data. The procedures and principles set out herein must be followed at all times by the Company and all 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 aims to ensure compliance with the Regulation. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:

    1. processed lawfully, fairly, and in a transparent manner in relation to the data subject;
    2. 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;
    3. adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
    4. 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;
    5. 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 Regulation in order to safeguard the rights and freedoms of the data subject; and
    6. 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.

  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:

    1. the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
    2. 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;
    3. processing is necessary for compliance with a legal obligation to which the controller is subject;
    4. processing is necessary to protect the vital interests of the data subject or of another natural person;
    5. 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;
    6. 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

    1. The Company collects and processes the personal data set out in Part 20 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).
    2. The Company only processes personal data for the specific purposes set out in Part 20 of this Policy or for other purposes expressly permitted by the Regulation.
  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 purposes as under Part 4, above.

  6. Accuracy of Data and Keeping Data Up To Date

    Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend that data or ensure that any such data is not readily accessible or useable by the Company, 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 that data or amend it to ensure that any such data is not readily accessible or useable by the Company or its employees.

  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 21 and 22 of this Policy.

  9. Accountability

    1. The Company's data protection officer is Casper Smallridge.
    2. The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
      1. The name and details of the Company, its data protection officer, and any applicable third party data controllers;
      2. The purposes for which the Company processes personal data;
      3. 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;
      4. Details (and categories) of any third parties that will receive personal data from the Company;
      5. Details of how long personal data will be retained by the Company; and
      6. 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:

    1. The purpose(s) for which personal data is being processed and the processing operations to be carried out on that data;
    2. Details of the legitimate interests being pursued by the Company;
    3. An assessment of the necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
    4. An assessment of the risks posed to individual Data Subjects; and
    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.
  11. The Rights of Data Subjects

    The Regulation sets out the following rights applicable to Data Subjects:

    1. The right to be informed;
    2. The right of access;
    3. The right to rectification;
    4. The right to erasure (also known as the 'right to be forgotten');
    5. The right to restrict processing;
    6. The right to data portability;
    7. The right to object; and
    8. Rights with respect to automated decision-making and profiling.

  12. Keeping Data Subjects Informed

    1. Upon request from a Data Subject, the Company shall promptly ensure that the following information is provided:
      1. Details of the Company including, but not limited to, the identity of Casper Smallridge, its Data Protection Officer, the purpose(s) for which the personal data is being collected and will be processed (as detailed in this Policy) and the legal basis justifying that collection and processing;
      2. Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
      3. Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
      4. Details of the length of time the personal data will be held by the Company (or, where there is no predetermined period, details of how that length of time will be determined);
      5. Details of the data subject's rights under the Regulation;
      6. f)Details of the data subject's right to withdraw their consent to the Company's processing of their personal data at any time;
      7. Details of the data subject's right to complain to the Information Commissioner's Office (the 'supervisory authority' under the Regulation); and
      8. Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it.
  13. Data Subject Access

    1. A data subject may make a subject access request ("SAR") at any time to find out more about the personal data which the Company holds about them. The Company is normally required to respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension).
    2. All subject access requests received must be forwarded to Casper Smallridge, the Company's data protection officer.
    3. The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
  14. Rectification of Personal Data

    1. If a data subject informs the Company that personal data held by the Company is inaccurate or incomplete, requesting that it be rectified, the personal data in question shall be rectified, and the data subject informed of that rectification, within one month of receipt the data subject's notice (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
    2. In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification of that personal data.
  15. Erasure of Personal Data

    1. Data Subjects may request that the Company erases the personal data it holds about them in the following circumstances:
      1. It is no longer necessary for the Company to hold that personal data with respect to the purpose for which it was originally collected or processed;
      2. The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
      3. The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 17 of this Policy for further details concerning Data Subjects' rights to object);
      4. The personal data has been processed unlawfully;
      5. The personal data needs to be erased in order for the Company to comply with a particular legal obligation.
    2. Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with insofar as possible by the Company and the data subject informed of the action taken by the Company within one month of receipt of the data subject's request (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
    3. In the event that any personal data that is to be erased or made inaccessible to the Company in response to a data subject request has been disclosed to third parties, those parties shall be informed of the action taken (unless it is impossible or would require disproportionate effort to do so).
  16. Restriction of Personal Data Processing

    1. Data Subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data pertaining to that data subject that is necessary to ensure that no further processing of their personal data takes place.
    2. In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).
  17. Objections to Personal Data Processing

    1. Data Subjects have the right to object to the Company processing their personal data based on legitimate interests.
    2. Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing forthwith, unless it can be demonstrated that the Company's legitimate grounds for such processing override the data subject's interests, rights and freedoms or the processing is necessary for the conduct of legal claims.
    3. Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing forthwith.
  18. Automated Decision-Making

    1. If and when the Company uses personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on Data Subjects, Data Subjects have the right to challenge to such decisions under the Regulation, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.
    2. The right described in Part 18.1 does not apply in the following circumstances:
      1. The decision is necessary for the entry into, or performance of, a contract between the Company and the data subject;
      2. The decision is authorised by law; or
      3. The data subject has given their explicit consent.
  19. Profiling

    If and when the Company uses personal data for profiling purposes, the following shall apply:

    1. Clear information explaining the profiling will be provided, including its significance and the likely consequences;
    2. Appropriate mathematical or statistical procedures will be used;
    3. Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
    4. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling (see Parts 21 and 22 of this Policy for more details on data security).

  20. Personal Data

    The following personal data may be collected, held, and processed by the Company:

    1. Addresses;
    2. Telephone and mobile numbers;
    3. Email addresses

    and any such other personal data as the Company may reasonably require for it to provide its usual business services.

  21. Data Protection Measures

  22. The Company shall ensure that all its employees, agents, contractors, or other parties working on its behalf comply with the following when working with personal data:
    1. Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hardcopies are securely disposed of via a confidential waste disposal company engaged by the Company and electronic copies should be deleted securely.
    2. No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from Casper Smallridge.
    3. All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet or similar;
    4. No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of Casper Smallridge;
    5. Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;
    6. If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it. In addition, the Company's computers are programmed to 'lock' and enter 'sleep' mode if left unattended for any more than a short period of time;
    7. No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging employees working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Regulation (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken);
    8. All personal data stored electronically should be backed up every day with backups stored offsite. All electronic copies of personal data should be stored securely using passwords;
    9. All passwords used to protect personal data are changed regularly and do not use words or phrases that can be easily guessed or otherwise compromised; and
    10. Under no circumstances are any passwords shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department.
  23. Organisational Measures

    The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

    1. All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company's responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;
    2. Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
    3. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
    4. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
    5. Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;
    6. The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
    7. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;
    8. All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Regulation; and
    9. Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

  24. Data Breach Notification

    1. All personal data breaches must be reported immediately to the Company's data protection officer.
    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.
    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 23.2) 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.
    4. Data breach notifications shall include the following information:
      1. The categories and approximate number of Data Subjects concerned;
      2. The categories and approximate number of personal data records concerned;
      3. The name and contact details of the Company's data protection officer (or other contact point where more information can be obtained);
      4. The likely consequences of the breach; and
      5. 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 ___ 2ND October 2019. 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: Roger Bowen

    Position: Chairman

    Date: 2nd October, 2019