Patico LTD is fully committed to prepare for and, after 25 May 2018, to comply with the General Data Protection Regulation (GDPR). The GDPR applies to all organisations that process data relating to their employees, as well as to others including customers, contractors and clients. It sets out principles which should be followed by those who process data; it gives new and extended rights to those whose data is being processed.

To this end, the organisation endorses fully and adheres to the six principles of data protection, as set out in the Article 5 of the GDPR.

1. Data must be processed lawfully, fairly and in a transparent manner in relation to individuals.
2. Data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
3. Data must be adequate, relevant and limited to what is necessary inrelation to the purposes for which they are processed.
4. Data must be 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.
5. Data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
6. Data must be 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.
   
   These principles must be followed always when processing or using personal information. Therefore, through appropriate management and strict application of criteria and controls, the organisation will:

• observe fully the conditions regarding the fair collection and use of information including the giving of consent
• meet its legal obligations to specify the purposes for which information is used
• collect and process appropriate information only to the extent that it is needed to fulfil our operational needs or to comply with any legal requirements
• ensure the quality of information used
• ensure that the information is held for no longer than is necessary
• ensure that the rights of people about whom information is held can be fully exercised under the GDPR (i.e. the right to be informed that processing is being undertaken, to access one's personal information; to prevent processing in certain circumstances, and to correct, rectify, block or erase information that is regarded as incorrect)
• take appropriate technical and organisational security measures to safeguard personal information
• publicise and abide by individuals' right to appeal or complain to the supervisory authority (the Information Commissioner's Office (ICO)) in the event that agreement cannot be reached in a dispute regarding data protection
• ensure that personal information is not transferred abroad without suitable safeguards

Disaster Recovery

• The organisation backs up data every day and has multiple copies (at least one set for each day of the week and additional weekly ones to have at least a month's worth of data at any one time). Records of these are kept.
• Backups are kept off-site. Any kept-on site is in special heat-proof safes: fire-proofing alone is inadequate.
• Backups are verified regularly by the software and system supplier.
• Master copies of software are stored off-site or in a heat-proof safe.
• Firewalls and virus checkers are kept up to date and running, and users are trained in virus avoidance and detection.
• Computers are protected from physical harm, theft or damage, and from electrical surges using protective plugs.
• The organisation plans for how to deal with loss of electricity, external data links, server failure, and network problems. It uses paper forms where necessary for temporary record keeping.

Subject Consent

The GDPR sets a high standard for consent and requires a positive opt-in. Neither pre-ticked boxes nor any other method of default consent are allowed. As required by the GDPR, the organisation takes a "granular" approach i.e. it asks for separate consent for separate items and will not use vague or blanket requests for consent.

As well as keeping evidence of any consent, the organisation ensures that people can easily withdraw consent (and tells them how this can be done).

It should be noted, however, that consent is only one of the lawful bases on which data processing depends. In brief, the others include the following.

• Contract: if processing someone's personal data is necessary to fulfil the organisation's contractual obligations to them (e.g. to provide a quote).
• Legal obligation: if processing personal data is necessary to comply with a common law or statutory obligation.
• Vital interests: not one that will occur often as it refers to processing personal data to protect someone's life (and even then, it cannot be relied on regarding health data or other special category data if the individual is capable of giving consent.
• Legitimate interests: the most flexible lawful basis for processing and one which applies when data is used in ways people would reasonably expect and which have a minimal privacy impact, or where there is a compelling justification for the processing.

Subject Access

A client may request details of personal information which the organisation holds about him or her under the GDPR. A small fee may be payable and will be based on the administrative cost of providing the information. If an employee would like a copy of the information held on him or her, they should write to [address]. The requested information will be provided within one month. If there is any reason for delay, that will be communicated within the four-week time period. A request which is manifestly unfounded or excessive may be refused. The person concerned will then be informed of their right to contest this decision with the supervisory authority (the ICO).

If a client believes that any information held on him or her is incorrect or incomplete, then they should telephone or email the Director as soon as possible, using contact the details below. The organisation will promptly correct any information found to be incorrect.

Conclusion This policy sets out this organisation's commitment to protecting personal data and how that commitment is implemented in respect of the collection and use of personal data.