1.Introduction

This Policy sets out the obligations of William Lacey Group Ltd, a company registered in the United Kingdom under number 00297901, whose registered office is at Elmbridge House, Elmbridge Lane, Woking, Surrey, GU22 9AF (“the Company”) regarding retention of personal data collected, held, and processed by the Company in accordance with EU Regulation 2016/679 General Data Protection Regulation (“GDPR”). It also sets out the obligations of the Company’s wholly owned subsidiaries.The GDPRdefines “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.The GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, 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.Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no  longer  than  is  necessary  for  the  purposes  for  which  the  personal  data  is  processed.  In  certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right  to  have  their  personal  data  erased  (and  to  prevent  the processing  of  that  personal  data)  in  the following circumstances:

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a) Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);

b) When the data subject withdraws their consent;

c) When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;

d) When the personal data is processed unlawfully (i.e. in breach of the GDPR);

e) When the personal data has to be erased to comply with a legal obligation; orf)Where the personal data is processed for the provision of information society services to a child.This Policy sets out the type(s) of personal data held by the Company, the period(s) for which that personal data is to be retained, the criteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of. It also indicates, where appropriate, the legislation which governs the collection and retention of such information.

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2.Aims and Objectives

a) The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this  Policy  aims  to  ensure that  the  Company  complies  fully  with  its obligations and  the  rights  of data subjects under the GDPR.

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b) In addition to safeguarding the rights of data subjects under the GDPR, by ensuring that excessive amounts of data are not retained by the Company, this Policy also aims to improve the speed and efficiency of managing data.

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3.Scope

a) This Policy applies to all personal data held by the Company and by third-party data processors processing personal data on the Company’s behalf.

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b) Personal data is stored in the following ways and in the following locations:

i. Third-party servers, operated by our collaboration partners whose servers are in the UK and EEA
ii. Third-party servers operated by several suppliers of cloud-based business support services (e.g. Microsoft, Google, Amazon Web Services etc.) all of which have been checked for GDPR compliance and whose servers are in the UK, US and EEA.
iii. Computers permanently located in the Company’s premises at Arena, The Square, Basing View, Basingstoke, Hampshire, RG21 4EB;
iv. Laptop computers and other mobile devices provided by the Company to its employees;

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4.Data Subject Rights and Data Integrity

All personal data held by the Company is held in accordance with the requirements of the GDPR and data subjects’ rights thereunder.

a) Data  subjects  are  kept  fully  informed  of  their  rights,  of  what  personal  data  the  Company  holds about them, how that personal data is used and how long the Company will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined).

b) Data subjects are given control over their personal data held by the Company including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise  set by this Data  Retention Policy), the right to restrict the Company’s use of their personal data, the right to data portability,  and further rights relating to automated decision-making and profiling.

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5.Technical and Organisational Data Security Measures

a) The  following  technical  measures  are  in  place  within  the  Company  to  protect  the  security  of personal data:
i. All emails  containing  personal  data  must  have  this  information  stored  as  an  encrypted attachment and not in the body of the email;
ii. All emails containing personal data must be marked “confidential”;
iii. Personal data may only be transmitted over secure networks;
iv. Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;
v. Personal  data  contained  in  the  body  of  an  email,  whether  sent  or  received,  should  be copied  from  the  body  of  that  email  and  stored  securely.  The email  itself  and  associated temporary files should be deleted;
vi. Where  personal  data  is  to  be  sent  by  facsimile  transmission  the  recipient  should be informed in advance and should be waiting to receive it;
vii. Where personal data is to be transferred in hard copy form, it should be passed directly to the recipient;
viii. All  personal  data  transferred  physically  should  be  transferred  in  a  suitable container marked “confidential”;
ix. No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from the Data Protection Officer.
x. All hard copies of personal data, along with any electronic copies stored on physical media should be stored securely;
xi. 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 authorisation;xii.Personal data must be handled with care at all times and should not be left unattended or on view;
xiii. Computers   used   to   view   personal   data   must   always   be   locked   before   being   left unattended;
xiv. No personal data should be stored on any mobile device, whether such device belongs to the  Company  or  otherwise  without  the  formal  written  approval  of  the  Data  Protection Officer and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary;
xv. 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 Company’s Data Protection Policy and the GDPR;
xvi. All personal data stored electronically will be backed up and stored offsite. All backups will be encrypted;
xvii. All  electronic  copies  of  personal  data  should  be  stored  securely  using  passwords  and encryption;
xviii. Under no circumstances should any passwords be written down or shared. If a password is forgotten,  it  must  be  reset  using  the  applicable  method.  IT  staff  do  not  have  access  to passwords;
xix. All  software  should  be  kept  up-to-date.  Security-related  updates  should  be  installed  as soon as reasonably possible after becoming available;
xx. No  software  may  be  installed  on  any  Company-owned  computer  or  device without approval; and
xxi. Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of  the  Data  Protection  Officer  to  ensure  that  the  appropriate  consent  is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS. 

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b) The following organisational measures are in place within the Company to protect the security of personal data.:
i. All  employees  and  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 GDPR;
ii.  Only employees and other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company;
iii.  All employees and other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
iv.  All employees and other parties working on behalf of the Company handling personal data will be appropriately supervised;
v.   All employees and other parties working on behalf of the Company handling personal data should exercise care and caution when discussing any work relating to personal data at all times;
vi.  Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
vii. The performance of those employees and other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
viii. All employees and other parties working on behalf of the Company handling personal data will be bound by contract to comply with the GDPR;
ix. All agents, contractors, or other parties working on behalf of the Company handling  personal  data must  ensure  that any  and  all relevant  employees  are  held  to the same conditions as those relevant employees of the Company arising out of the GDPR;
x. Where  any  agent,  contractor or other  party working on  behalf  of  the  Company handling personal data fails in their obligations under the GDPR, 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.

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6.Data Disposal

Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or when a data subject exercises  their  right  to  have their  personal  data  erased,  personal  data  shall  be  deleted,  destroyed,  or otherwise disposed of as follows:
a) Personal data stored electronically (including any and all backups thereof) shall be deleted securely;

b) Special category personal data stored electronically (including any and all backups thereof) shall be deleted securely;

c) Personal  data  stored  in  hard copy  form  will  be  collected  and  securely  shredded  by  Shred  It UK services;

d) Special category personal data stored in hard copy form will be collected and securely shredded by Shred It UK services or equivalent secure UK shredding company.

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7.Data Retention

a) As stated above, and as required by law, the Company shall not retain any personal data for any longer  than  is  necessary  in  light  of  the  purpose(s)  for  which  that  data  is  collected,  held,  and processed.

b) Different  types  of  personal  data,  used  for  different  purposes,  will  necessarily  be  retained  for different periods and its retention periodically reviewed), as set out below.

c) When establishing and/or reviewing retention periods, the following shall be taken into account:
i.   The objectives and requirements of the Company;
ii.  The type of personal data in question;
iii. The purpose(s) for which the data in question is collected, held, and processed;
iv. The Company’s legal basis for collecting, holding, and processing that data;
v.  The category or categories of data subject to whom the data relates;

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d) If  a  precise  retention  period  cannot  be  fixed  for  a particular  type  of  data,  criteria  shall  be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.

e) Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).

f) In limited circumstances, it may also be necessary to retain personal data for longer periods where such  retention  is  for  archiving  purposes  that  are  in the  public  interest,  for  scientific  or  historical research   purposes,   or   for   statistical   purposes.   All   such   retention   will   be   subject   to   the implementation  of appropriate  technical  and  organisational  measures to  protect  the  rights  and freedoms of data subjects, as required by the GDPR. 

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8.Roles and Responsibilities

a) The Company’s Data Protection Officer is Chris Lacey (laceyc@williamlaceygroup.co.uk).

b) The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and  for  monitoring  compliance  with this Policy, the Company’s other Data Protection-related policies and with the GDPR and other applicable data protection legislation.

c) The Data Protection Officer shall be  directly responsible for ensuring compliance  with the above data retention periods throughout the Company.

d) Any questions regarding this Policy, the retention of personal data, or any other aspect
of GDPR compliance should be referred to the Data Protection Officer.

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9.Implementation

This Policy shall be deemed effective as of 25/05/2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

 
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The information in emails which we send is confidential and may be legally privileged.

It is intended solely for the addressee. Access to such an email by anyone else is unauthorised. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken or reliance on it is prohibited and may be unlawful.

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William Lacey Group Ltd may intercept any e-mail or other communications which you send to or receive via the Company’s telecommunications systems for certain permitted lawful purposes. By so corresponding you also give your consent to Boom, monitoring and recording of any correspondence using these systems. Boom is a trading name of William Lacey Group Ltd, is registered in England and Wales, company number  00297901. Registered Office: Elmbridge House, Elmbridge Lane, Woking, Surrey, GU22 9AF, United Kingdom.