Data Protection Policy
This Policy sets out the obligations of Kennerty Consulting Ltd., a company registered in England & Wales under number 9345386, whose registered office is at 71-75 Shelton Street, Covent Garden, WC2H 9JQ, United Kingdom (“the Company”) regarding data protection and the rights of its website visitors, customers and business contacts (“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
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:
3. The Rights of Data Subjects
The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):
4. Lawful, Fair, and Transparent Data Processing
5. Specified, Explicit, and Legitimate Purposes
6. Adequate, Relevant, and Limited Data Processing
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) as under Part 5, above, and as set out in Part 21, below.
7. Accuracy of Data and Keeping Data Up-to-Date
8. Data Retention
9. Secure Processing
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 in Parts 22 to 27 of this Policy.
10. Accountability and Record-Keeping
11. Data Protection Impact Assessments
12. Keeping Data Subjects Informed
13. Data Subject Access
14. Rectification of Personal Data
15. Erasure of Personal Data
16. Restriction of Personal Data Processing
17. Data Portability
18. Objections to Personal Data Processing
19. Automated Decision-Making
21. Personal Data Collected, Held, and Processed
For details of personal data that is collected, held, and processed by the Company, please refer to the Company’s Data Retention Policy.
22. Data Security - Transferring Personal Data and Communications
The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:
23. Data Security - Storage
The Company shall ensure that the following measures are taken with respect to the storage of personal data:
24. Data Security - Disposal
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 Policy.
25. Data Security - Use of Personal Data
The Company shall ensure that the following measures are taken with respect to the use of personal data:
26. Data Security - IT Security
The Company shall ensure that the following measures are taken with respect to IT and information security:
27. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
28. Transferring Personal Data to a Country Outside the EEA
29. Data Breach Notification
30. Implementation of Policy
This Policy shall be deemed effective as of 25th May 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
Last Updated: 25th May 2018