1. Data protection principles: The Company is committed to processing data in accordance with its responsibilities under the GDPR. Article 4 of the GDPR requires that personal data shall be:

1. 1. Processed lawfully, fairly, and in a transparent manner in relation to individuals;

1. 1.  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;

1. 1.  Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;

1. 1.  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;

1. 1.  Kept in a form that 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 organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

1. 1.  Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.”

 
2. General provisions

1. 1. This policy applies to all personal data processed by the Company.

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

1. 1. This policy shall be reviewed at least annually.

 
3. Lawful purposes

1. 1. All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task, or legitimate interests;

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

 
4. Data minimization

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

 
5. Accuracy

1. 1. The Company shall take reasonable steps to ensure personal data is accurate.

1. 1. 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.

 
6. Security

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

1. 1. Access to personal data shall be limited to personnel who need access, and appropriate security should be in place to avoid unauthorized sharing of information.

1. 1. When personal data is deleted, this should be done safely such that the data is irrecoverable.

 
7. Breach

1. 1. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, or unauthorized disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and notify them.