DATA PRIVACY NOTICE
Personal data relates to a living individual who can be identified from that data. Identification can beby the information alone or in conjunction with any other information in the data controller’spossession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR)
Who are we?
Connect Community Trust is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.
What personal data do we collect?
We need certain personal data to provide you with the best service that we can and also for funding and contractual reasons. We collect the following:
Name (First and Surname)
Housing Association (is applicable)
National Insurance Number (where applicable)
Work History and Training Requirement (where applicable)
Type of Benefit and employment status (where applicable)
Emergency Contact details (where applicable)
Company Name (where applicable)
How do we process and retain your personal data?
Connect Community Trust complies with its obligations under [the GDPR] by keeping personal data up to date;
by storing and destroying it securely; by not collecting or retaining excessive amounts of data; our client management database Hanlon is password secure and the relevant procedures are in place with our provider to securely store the data; any membership forms are stored in a lockable storage cupboard
by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. This includes encryption and password protection of any e-mail transfers that include personal data.
We use your personal data for the following purposes:
To enable us to provide a voluntary service for the benefit of the public as specified in our constitution including job clubs, sports, youth, elderly and adult services; To administer membership records;
To fundraise and promote the interests of the charity; To manage ouremployees andv olunteers;
To maintain our own accounts and records.
To operate the Connect Community Trust, Connect Entertainment, ReConnect Glasgow web site and social media
To inform individuals of news, events, activities or services running at Connect Community Trust To contact individuals via surveys to conduct research about their opinions of current services or of potential new services that may be offered.
To deliver training provision that is purchased by third parties, such as DWP
What is the legal basis for processing your personal data?
These fall under either article 6 or article 9 – dealt with separately below.Article 6 Processing
We require consent from individuals for the storing of data; Appendix A “Consent Form” isrequired to be completed.
Processing is necessary for the performance of contracts and funding that we have in place as we are required to provide statistical evidence on our delivery
Processing is necessary for compliance with a legal obligation; due to the nature of our funding and contracts we are required to provide statistical information on the clients that we work with to ensure we meet funding and contractual outcomes. Please note that only statistical information is provided, not your personal details. In addition, OSCR require us to keep information on our Board of Directors
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 data controller;
Article 9 Processing
Explicit consent of the data subject Appendix A “Consent Form” is required to be completed in order for us to share information on events, our newsletter or opportunities that we want to make you aware of
Processing is necessary for the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject; Grant Funding reporting and monitoring requirements state that "the Grantee must keep and maintain for a period of 3 years adequate and proper records and books of account"
Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement;
Processing is necessary to protect the vital interests of a data subject or another individual where the data subject is physically or legally incapable of giving consent;
Processing is carried out by a not-for-profit body and the processing relates only to current clients (or those who have regular contact with us in connection with those purposes); and there is no disclosure to a third party without consent.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with other organisations or funders to comply with a legitimate contractual or legal obligation. This includes:
- DWP for training provision (only through dedicated training provision purchased by DWP)
- Housing Associations for job club support or income advice service (with prior written approval from client)
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for a period of 3 years in order to comply with funding and contractual legal requirements and/or safeguarding purposes.
HR Data is kept for a maximum of 3 years following the termination of employment, some personal information will be destroyed after 2 years.
Your rights and your personal data
Unless subject to an exemption [under the GDPR], you have the following rights with respect to your personal data: -
The right to request a copy of your personal data which Connect Community Trust holds about you;
The right to request that Connect Community Trust corrects any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary Connect Community Trust to retain such data;
The right to withdraw your consent to the processing at any time
The right to request that the data controller provide the data subject with his/her personal
data and where possible, to transmit that data directly to another data controller, (known as
the right to data portability)
The right, where there is a dispute in relation to the accuracy or processing of your personal
data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable)
The right to lodge a complaint with the Information Commissioners Office.
Transfer of Data Abroad. If the personal data is to be transferred to countries or territories
outside the EU you must include details of how the data will be protected, together with details of how to obtain copies of the relevant safeguards
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
Where and whenever necessary, we will seek your prior consent to the new processing.
To exercise all relevant rights, queries of complaints please in the first instance, contact us at:
Connect Community Trust 17-19 Newhills Road GLASGOW
Tel: 0141 781 9918
DATA PROTECTION POLICY
This Policy sets out the obligations of Connect Community Trust (the Company) regarding data protection and the rights of its data subjects in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (GDPR).
The GDPR 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 the Company’s obligations regarding the collection, processing,transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other 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
2.1 This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:
2.1.1 Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
2.1.2 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.
2.1.3 Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
2.1.4 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 it is processed, is erased, or rectified without delay.
2.1.5 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 GDPR in order to safeguard the rights and freedoms of the data subject.
2.1.6 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. The Rights of Data Subjects
3.1 The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):
3.1.1 The right to be informed;
3.1.2 The right of access;
3.1.3 The right to rectification;
3.1.4 The right to erasure (also known as the ‘right to be forgotten’);
3.1.5 The right to restrict processing;
3.1.6 The right to data portability;
3.1.7 The right to object;
3.1.8 Rights with respect to automated decision-making and profiling.
4. Lawful, Fair, and Transparent Data Processing
4.1 The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:
4.1.1 The data subject has given consent to the processing of their personal data for one or more specific purposes;
4.1.2 The 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 with them;
4.1.3 The processing is necessary for compliance with a legal obligation to which the data controller is subject;
4.1.4 The processing is necessary to protect the vital interests of the data subject or of another natural person;
4.1.5 The 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 data controller; or
4.1.6 The processing is necessary for the purposes of the legitimate interests pursued by the data 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.
4.2 If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s race, ethnicity,politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:
4.2.1 The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);
4.2.2 The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);
4.2.3 The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
4.2.4 The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;
4.2.5 The processing relates to personal data which is clearly made public by the data subject;
4.2.6 The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;
4.2.7 The processing is necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;
4.2.8 The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;
4.2.9 The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or
4.2.10 The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.
5. Specified, Explicit, and Legitimate Purposes
5.1 The Company collects and processes the personal data set out in the Company’s
Privacy Notice. This includes:
5.1.1 Personal data collected directly from data subjects;
5.1.2 Personal data obtained from third parties.
5.2 The Company only collects, processes, and holds personal data for the specific purposes as set out in the Company’s Privacy Notice (or for other purposes expressly permitted by the GDPR).
5.3 Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data.
6. Adequate, Relevant, and Limited Data Processing
6.1 The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed).
7. Accuracy of Data and Keeping Data Up-to-Date
7.1 The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject.
7.2 The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.
8. Data Retention
8.1 The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.
8.2 When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
8.3 For full details of the Company’s approach to data retention, including retentionperiods for specific personal data types held by the Company, please refer to our Data Retention Process included within our Privacy Notice.
9. Secure Processing
9.1. The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided.
10. Accountability and Record-Keeping
10.1 The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
10.1.1 The name and details of the Company, and any applicable third-party data processors;
10.1.2 The purposes for which the Company collects, holds, and processes personal data;
10.1.3 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;
10.1.4 Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
10.1.5 DetailsofhowlongpersonaldatawillberetainedbytheCompany(pleaserefer to the Company’s Data Retention Process located within the Privacy Notice);
10.1.6 Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.
11. Data Protection Impact Assessments
11.1 The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data [which involve the use of new technologies and the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the GDPR].
11.2 Data Protection Impact Assessments shall address the following:
11.2.1 The type(s) of personal data that will be collected, held, and processed;
11.2.2 The purpose(s) for which personal data is to be used;
11.2.3 The Company’s objectives;
11.2.4 How personal data is to be used;
11.2.5 The parties (internal and/or external) who are to be consulted;
11.2.6 The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
11.2.7 Risks posed to data subjects;
11.2.8 Risks posed both within and to the Company; and
11.2.9 Proposed measures to minimise and handle identified risks.
12. Keeping Data Subjects Informed
12.1 The Company shall provide the information to every data subject:
12.1.1 Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and
12.1.2 Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:
a) if the personal data is used to communicate with the data subject, when the first communication is made; or
b) if the personal data is to be transferred to another party, before that transfer is made; or
c) as soon as reasonably possible and in any event not more than one month after the personal data is obtained.
12.2 The following information shall be provided via access to the Privacy Notice which provides all of the information below ie a link to or hard copy:
12.2.1 Details of the Company;
12.2.2 The purpose(s) for which the personal data is being collected and will be processed and the legal basis justifying that collection and processing;
12.2.3 Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
12.2.4 Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
12.2.5 Where the personal data is to be transferred to one or more third parties, details of those parties;
12.2.6 Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the EEA), details of that transfer, including but not limited to the safeguards in place;
12.2.7 Details of data retention;
12.2.8 Details of the data subject’s rights under the GDPR;
12.2.9 Details of the data subject’s right to withdraw their consent to the Company’sprocessing of their personal data at any time;
12.2.10Details of the data subject’s right to complain to the InformationCommissioner’s Office (the supervisory authority under the GDPR);
12.2.11Where 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; and
12.2.12Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.
13. Data Subject Access
13.1 Data subjects may make subject access requests (SARs) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.
13.2 Data subjects wishing to make a SAR may do so in writing, using the Company’s SubjectAccess Request Form, or other written communication. SARs should be addressed to Pauline Smith, Connect Community Trust, 17-19 Newhills Road, GLASGOW, G33 4HH
13.3 Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.
13.4 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
14.1 Data subjects have the right to require the Company to rectify any of their personal
data that is inaccurate or incomplete.
14.2 The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
14.3 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.
15. Erasure of Personal Data
15.1 Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:
15.1.1 It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
15.1.2 The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
15.1.3 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);
15.1.4 The personal data has been processed unlawfully;
15.1.5 The personal data needs to be erased in order for the Company to comply with
a particular legal obligation.
15.2 Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can beextended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
15.3 In the event that any personal data that is to be erased in response to a data subject’srequest has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).
16. Restriction of Personal Data Processing
16.1 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 concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.
16.2 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
17.1 Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.
17.2 Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unlessit can be demonstrated that the Company’s legitimate grounds for such processingoverride the data subject’s interests, rights, and freedoms, or that the processing isnecessary for the conduct of legal claims.
17.3 Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.
18. Data Security - Transferring Personal Data and Communications
21.1 The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:
21.1.1 All emails containing personal data must be marked “confidential” and deleted once the personal data is stored securely;
21.1.2 Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
21.1.3 Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
19. Data Security - Storage
22.1 The Company shall ensure that the following measures are taken with respect to the storage of personal data:
22.1.1 All electronic copies of personal data should be stored securely using passwords and data encryption where applicable;
22.1.2 All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely or locked away;
22.1.3 Allpersonaldatastoredelectronicallyshouldbebackedupregularly.Allbackups should be encrypted where necessary;
22.1.4 No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties 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 GDPR (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).
20. Data Security - Disposal
23.1 When 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. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Process included within the Privacy Notice.
21. Data Security - Use of Personal Data
24.1 The Company shall ensure that the following measures are taken with respect to the use of personal data
24.1.1 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 (CEO)
24.1.2 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 (CEO);
24.1.3 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;
24.1.4 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; and
24.1.5 Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of (CEO) to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service.
25 Data Security - IT Security
25.1 The Company shall ensure that the following measures are taken with respect to IT and information security:
25.1.1 All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. All software used by the Company is designed to require such passwords.;
25.1.2 Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
25.1.3 All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates as soon as reasonably and practically possible, unless there are valid technical reasons not to do so; and
26 Organisational Measures
26.1 The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
26.1.1 All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities andthe Company’s responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy;
26.1.2 Onlyemployees,agents,sub-contractors,orotherpartiesworkingonbehalfof 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;
26.1.3 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
26.1.4 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
26.1.5 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
26.1.6 Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
26.1.7 AllpersonaldataheldbytheCompanyshallbereviewedperiodically,assetout in the Company’s Data Retention Process included within the Privacy Notice;
26.1.8 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 GDPR and this Policy by contract;
26.1.9 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 GDPR; and
26.1.10 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.
27 Implementation of Policy
28.1 This Policy shall be deemed effective as of 21st May 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.