1.
Interpretation
1.1
Definitions:
Automated Decision-Making
(ADM): when a decision is made which is based solely on Automated
Processing (including profiling) which produces legal effects or significantly
affects an individual. The UK GDPR prohibits Automated Decision-Making (unless
certain conditions are met) but not Automated Processing.
Automated Processing:
any form of automated processing of Personal Data consisting of the use of
Personal Data to evaluate certain personal aspects relating to an individual,
in particular to analyse or predict aspects concerning that individual's
performance at work, economic situation, health, personal preferences,
interests, reliability, behaviour, location or movements. Profiling is an
example of Automated Processing.
Company name: Edu
Lettings (UK) Limited.
Company Personnel:
all employees, workers, contractors, agency workers, consultants, directors,
members and others.
Consent: agreement
which must be freely given, specific, informed and be an unambiguous indication
of the Data Subject's wishes by which they, by a statement or by a clear
positive action, signify agreement to the Processing of Personal Data relating
to them.
Controller: the
person or organisation that determines when, why and how to process Personal
Data. It is responsible for establishing practices and policies in line with
the UK GDPR. We are the Controller of all Personal Data relating to our Company
Personnel and Personal Data used in our business for our own commercial
purposes.
Criminal Convictions Data:
means personal data relating to criminal convictions and offences and includes
personal data relating to criminal allegations and proceedings.
Data Subject: a
living, identified or identifiable individual about whom we hold Personal Data.
Data Subjects may be nationals or residents of any country and may have legal
rights regarding their Personal Data.
Data Privacy Impact
Assessment (DPIA): tools and assessments used to identify and reduce
risks of a data processing activity. DPIA can be carried out as part of Privacy
by Design and should be conducted for all major system or business change
programmes involving the Processing of Personal Data.
Data Protection Officer
(DPO): the person required to be appointed in specific circumstances
under the UK GDPR. Where a mandatory DPO has not been appointed, this term
means a data privacy manager or other voluntary appointment of a DPO or refers
to the Company data privacy team with responsibility for data protection
compliance.
Explicit Consent:
consent which requires a very clear and specific statement (that is, not just
action).
UK GDPR: the retained
EU law version of the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards
specified in the UK GDPR.
Personal Data: any
information identifying a Data Subject or information relating to a Data
Subject that we can identify (directly or indirectly) from that data alone or
in combination with other identifiers we possess or can reasonably access.
Personal Data includes Special Categories of Personal Data and Pseudonymised
Personal Data but excludes anonymous data or data that has had the identity of
an individual permanently removed. Personal data can be factual (for example, a
name, email address, location or date of birth) or an opinion about that
person's actions or behaviour.
Personal Data Breach:
any act or omission that compromises the security, confidentiality, integrity
or availability of Personal Data or the physical, technical, administrative or
organisational safeguards that we or our third-party service providers put in
place to protect it. The loss, or unauthorised access, disclosure or
acquisition, of Personal Data is a Personal Data Breach.
Privacy by Design:
implementing appropriate technical and organisational measures in an effective
manner to ensure compliance with the UK GDPR.
Privacy Notices (also
referred to as Fair Processing Notices) or Privacy Policies: separate
notices setting out information that may be provided to Data Subjects when the
Company collects information about them. These notices may take the form of
general privacy statements applicable to a specific group of individuals (for
example, employee privacy notices or the website privacy policy) or they may be
stand-alone, one-time privacy statements covering Processing related to a specific
purpose.
Processing or Process:
any activity that involves the use of Personal Data. It includes obtaining,
recording or holding the data, or carrying out any operation or set of
operations on the data including organising, amending, retrieving, using,
disclosing, erasing or destroying it. Processing also includes transmitting or
transferring Personal Data to third parties.
Pseudonymisation or
Pseudonymised: replacing information that directly or indirectly
identifies an individual with one or more artificial identifiers or pseudonyms
so that the person, to whom the data relates, cannot be identified without the
use of additional information which is meant to be kept separately and secure.
Special Categories of
Personal Data: information revealing racial or ethnic origin, political
opinions, religious or similar beliefs, trade union membership, physical or
mental health conditions, sexual life, sexual orientation, biometric or genetic
data.
2.
Introduction
This Data Protection Policy
sets out how Edu Lettings (UK) Limited, ("we", "our",
"us", "the Company") handle the Personal Data of our
customers, suppliers, employees, workers and other third parties.
This Data Protection Policy
applies to all Personal Data we Process regardless of the media on which that
data is stored or whether it relates to past or present employees, workers,
customers, clients or supplier contacts, shareholders, website users or any
other Data Subject.
This Data Protection Policy
applies to all Company Personnel ("you", "your"). You must
read, understand and comply with this Data Protection Policy when Processing
Personal Data on our behalf and attend training on its requirements. This Data
Protection Policy sets out what we expect from you for the Company to comply
with applicable law. Your compliance with this Data Protection Policy is
mandatory. Related Policies and Privacy Guidelines are available to help you
interpret and act in accordance with this Data Protection Policy. You must also
comply with all such Related Policies and Privacy Guidelines. Any breach of
this Data Protection Policy may result in disciplinary action.
Where you have a specific
responsibility in connection with Processing such as capturing Consent,
reporting a Personal Data Breach, conducting a DPIA as referenced in this Data
Protection Policy or otherwise then you must comply with the Related Policies
and Privacy Guidelines.
This Data Protection Policy
(together with Related Policies and Privacy Guidelines) is an internal document
and cannot be shared with third parties, clients or regulators without prior
authorisation from the DPO.
3.
Scope
We recognise that the correct
and lawful treatment of Personal Data will maintain confidence in the
organisation and will provide for successful business operations. Protecting
the confidentiality and integrity of Personal Data is a critical responsibility
that we take seriously at all times. The Company is exposed to potential fines
of up to £17.5 million or 4% of total worldwide annual turnover, whichever is
higher and depending on the breach, for failure to comply with the provisions
of the UK GDPR.
The DPO is responsible for
overseeing this Data Protection Policy and, as applicable, developing Related
Policies and Privacy Guidelines. That post is held by Nick Bowen, and they can
be reached at 07581309165 and nickbowen@edu-lettings.org
Please contact the DPO with
any questions about the operation of this Data Protection Policy or the UK GDPR
or if you have any concerns that this Data Protection Policy is not being or
has not been followed. In particular, you must always contact the DPO in the
following circumstances:
(a) if you are unsure of the lawful basis which you
are relying on to process Personal Data (including the legitimate interests
used by the Company) (see paragraph 5.1);
(b) if you need to rely on Consent and/or need to
capture Explicit Consent (see paragraph 6);
(c) if you need to draft Privacy Notices (see paragraph 7);
(d) if you are unsure about the retention period for
the Personal Data being Processed (see paragraph 11);
(e) if you are unsure about what security or other
measures you need to implement to protect Personal Data (see paragraph 12.1);
(f) if there has been a Personal Data Breach (paragraph 13);
(g) if you are unsure on what basis to transfer
Personal Data outside the UK (see paragraph 14);
(h) if you need any assistance dealing with any
rights invoked by a Data Subject (see paragraph 15);
(i) whenever you are engaging in a significant new,
or change in, Processing activity which is likely to require a DPIA (see paragraph 19) or plan to use Personal Data for purposes other than what it was
collected for;
(j) if you plan to undertake any activities
involving Automated Processing including profiling or Automated Decision-Making
(see paragraph 20);
(k) if you need help complying with applicable law
when carrying out direct marketing activities (see paragraph 21); or
(l) if you need help with any contracts or other
areas in relation to sharing Personal Data with third parties (including our
vendors) (see paragraph 22).
4.
Personal data
protection principles
We adhere to the principles
relating to Processing of Personal Data set out in the UK GDPR which require
Personal Data to be:
(a) Processed lawfully, fairly and in a transparent
manner (Lawfulness, Fairness and Transparency);
(b) collected only for specified, explicit and
legitimate purposes (Purpose Limitation);
(c) adequate, relevant and limited to what is
necessary in relation to the purposes for which it is Processed (Data
Minimisation);
(d) accurate and where necessary kept up to date
(Accuracy);
(e) not kept in a form which permits identification
of Data Subjects for longer than is necessary for the purposes for which the
data is Processed (Storage Limitation);
(f) Processed in a manner that ensures its security
using appropriate technical and organisational measures to protect against
unauthorised or unlawful Processing and against accidental loss, destruction or
damage (Security, Integrity and Confidentiality);
(g) not transferred to another country without appropriate
safeguards being in place (Transfer Limitation); and
(h) made available to Data Subjects and allow Data
Subjects to exercise certain rights in relation to their Personal Data (Data
Subject's Rights and Requests).
We are responsible for and
must be able to demonstrate compliance with the data protection principles
listed above (Accountability).
5.
Lawfulness, fairness,
transparency
5.1
Lawfulness and
fairness
Personal data must be Processed lawfully, fairly and in
a transparent manner in relation to the Data Subject.
You may only collect, Process and share Personal Data
fairly and lawfully and for specified purposes. The UK GDPR restricts our
actions regarding Personal Data to specified lawful purposes. These
restrictions are not intended to prevent Processing but ensure that we Process
Personal Data fairly and without adversely affecting the Data Subject.
The UK GDPR allows Processing for specific purposes,
some of which are set out below:
(a) the Data Subject has given his or her Consent;
(b) the Processing is necessary for the performance
of a contract with the Data Subject;
(c) to meet our legal compliance obligations;
(d) to protect the Data Subject's vital interests;
(e) to pursue our legitimate interests (or those of
a third party) for purposes where they are not overridden because the
Processing prejudices the interests or fundamental rights and freedoms of Data
Subjects. The purposes for which we process Personal Data for legitimate interests
need to be set out in applicable Privacy Notices; or
You must identify and document the legal ground being
relied on for each Processing activity.
6.
Consent
A Controller must only process Personal Data on the basis
of one or more of the lawful bases set out in the UK GDPR, which include
Consent.
A Data Subject consents to Processing of their Personal
Data if they indicate agreement clearly either by a statement or positive
action to the Processing. Consent requires affirmative action so silence,
pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is
given in a document which deals with other matters, then the Consent must be
kept separate from those other matters.
Data Subjects must be easily able to withdraw Consent to
Processing at any time and withdrawal must be promptly honoured. Consent may
need to be refreshed if you intend to Process Personal Data for a different and
incompatible purpose which was not disclosed when the Data Subject first
consented.
When processing Special Category Data or Criminal
Convictions Data, we will usually rely on a legal basis for processing other
than Explicit Consent or Consent if possible. Where Explicit Consent is relied
on, you must issue a Privacy Notice to the Data Subject to capture Explicit
Consent.
You will need to evidence Consent captured and keep records
of all Consents in accordance with Related Policies and Privacy Guidelines so
that the Company can demonstrate compliance with Consent requirements.
7.
Transparency
(notifying Data Subjects)
The UK GDPR requires Controllers to provide detailed,
specific information to Data Subjects depending on whether the information was
collected directly from Data Subjects or from elsewhere. The information must
be provided through appropriate Privacy Notices which must be concise,
transparent, intelligible, easily accessible, and in clear and plain language
so that a Data Subject can easily understand them.
Whenever we collect Personal Data directly from Data
Subjects, including for HR or employment purposes, we must provide the Data
Subject with all the information required by the UK GDPR including the identity
of the Controller and DPO, how and why we will use, Process, disclose, protect
and retain that Personal Data through a Privacy Notice which must be presented
when the Data Subject first provides the Personal Data.
When Personal Data is collected indirectly (for example,
from a third party or publicly available source), we must provide the Data
Subject with all the information required by the UK GDPR as soon as possible
after collecting or receiving the data. We must also check that the Personal
Data was collected by the third party in accordance with the UK GDPR and on a basis
which contemplates our proposed Processing of that Personal Data.
If you are collecting Personal Data from Data Subjects,
directly or indirectly, then you must provide Data Subjects with a Privacy
Notice in accordance with our Related Policies and Privacy Guidelines.
8.
Purpose limitation
Personal Data must be
collected only for specified, explicit and legitimate purposes. It must not be
further Processed in any manner incompatible with those purposes.
You cannot use Personal Data
for new, different or incompatible purposes from that disclosed when it was
first obtained unless you have informed the Data Subject of the new purposes
and they have Consented where necessary.
9.
Data minimisation
Personal Data must be
adequate, relevant and limited to what is necessary in relation to the purposes
for which it is Processed.
You may only Process Personal
Data when performing your job duties requires it. You cannot Process Personal
Data for any reason unrelated to your job duties.
You may only collect Personal
Data that you require for your job duties: do not collect excessive data. Ensure
any Personal Data collected is adequate and relevant for the intended purposes.
You must ensure that when
Personal Data is no longer needed for specified purposes, it is deleted or
anonymised in accordance with the Company's data retention guidelines.
10.
Accuracy
Personal Data must be accurate
and, where necessary, kept up to date. It must be corrected or deleted without
delay when inaccurate.
You will ensure that the
Personal Data we use and hold is accurate, complete, kept up to date and
relevant to the purpose for which we collected it. You must check the accuracy
of any Personal Data at the point of collection and at regular intervals
afterwards. You must take all reasonable steps to destroy or amend inaccurate
or out-of-date Personal Data.
11.
Storage limitation
Personal Data must not be kept
in an identifiable form for longer than is necessary for the purposes for which
the data is processed.
The Company will maintain
retention policies and procedures to ensure Personal Data is deleted after a
reasonable time for the purposes for which it was being held, unless a law
requires that data to be kept for a minimum time.
You must not keep Personal
Data in a form which permits the identification of the Data Subject for longer
than needed for the legitimate business purpose or purposes for which we
originally collected it including for the purpose of satisfying any legal,
accounting or reporting requirements.
You will take all reasonable
steps to destroy or erase from our systems all Personal Data that we no longer
require in accordance with all the Company's applicable records retention
schedules and policies. This includes requiring third parties to delete that
data where applicable.
You will ensure Data Subjects
are informed of the period for which data is stored and how that period is
determined in any applicable Privacy Notice.
12.
Security
integrity and confidentiality
12.1
Protecting
Personal Data
Personal Data must be secured by appropriate technical
and organisational measures against unauthorised or unlawful Processing, and
against accidental loss, destruction or damage.
We will develop, implement and maintain safeguards
appropriate to our size, scope and business, our available resources, the
amount of Personal Data that we own or maintain on behalf of others and
identified risks (including use of encryption and Pseudonymisation where
applicable). We will regularly evaluate and test the effectiveness of those
safeguards to ensure security of our Processing of Personal Data. You are
responsible for protecting the Personal Data we hold. You must implement
reasonable and appropriate security measures against unlawful or unauthorised
Processing of Personal Data and against the accidental loss of, or damage to,
Personal Data. You must exercise particular care in protecting Special
Categories of Personal Data and Criminal Convictions Data from loss and
unauthorised access, use or disclosure.
You must follow all procedures and technologies we put
in place to maintain the security of all Personal Data from the point of
collection to the point of destruction. You may only transfer Personal Data to
third-party service providers who agree to comply with the required policies
and procedures and who agree to put adequate measures in place, as requested.
You must maintain data security by protecting the
confidentiality, integrity and availability of the Personal Data, defined as
follows:
(a) Confidentiality means that only people who have
a need to know and are authorised to use the Personal Data can access it;
(b) Integrity means that Personal Data is accurate
and suitable for the purpose for which it is processed; and
(c) Availability means that authorised users are
able to access the Personal Data when they need it for authorised purposes.
13.
Reporting a Personal
Data Breach
The UK GDPR requires Controllers to notify any Personal
Data Breach to the Information Commissioner and, in certain instances, the Data
Subject.
We have put in place procedures to deal with any suspected
Personal Data Breach and will notify Data Subjects or any applicable regulator
where we are legally required to do so.
If you know or suspect that a Personal Data Breach has
occurred, do not attempt to investigate the matter yourself. Immediately
contact the person or team designated as the key point of contact for Personal
Data Breaches, your line manager. You should preserve all evidence relating to
the potential Personal Data Breach.
14.
Transfer limitation
The UK GDPR restricts data
transfers to countries outside the UK to ensure that the level of data
protection afforded to individuals by the UK GDPR is not undermined. You
transfer Personal Data originating in one country across borders when you
transmit, send, view or access that data in or to a different country.
You may only transfer Personal
Data outside the UK if one of the following conditions applies:
(a) he UK has issued regulations confirming that
the country to which we transfer the Personal Data ensures an adequate level of
protection for the Data Subject's rights and freedoms;
(b) appropriate safeguards are in place such as
binding corporate rules (BCR), standard contractual clauses approved for use in
the UK, an approved code of conduct or a certification mechanism, a copy of
which can be obtained from the DPO;
(c) the Data Subject has provided Explicit Consent
to the proposed transfer after being informed of any potential risks; or
(d) the transfer is necessary for one of the other
reasons set out in the UK GDPR including the performance of a contract between
us and the Data Subject, reasons of public interest, to establish, exercise or
defend legal claims or to protect the vital interests of the Data Subject where
the Data Subject is physically or legally incapable of giving Consent and, in
some limited cases, for our legitimate interest.
15.
Data Subject's rights
and requests
Data Subjects have rights when
it comes to how we handle their Personal Data. These include rights to:
(a) withdraw Consent to Processing at any time;
(b) receive certain information about the
Controller's Processing activities;
(c) request access to their Personal Data that we
hold;
(d) prevent our use of their Personal Data for
direct marketing purposes;
(e) ask us to erase Personal Data if it is no longer
necessary in relation to the purposes for which it was collected or Processed
or to rectify inaccurate data or to complete incomplete data;
(f) restrict Processing in specific circumstances;
(g) challenge Processing which has been justified on
the basis of our legitimate interests or in the public interest;
(h) request a copy of an agreement under which
Personal Data is transferred outside of the UK;
(i) object to decisions based solely on Automated
Processing, including profiling (ADM);
(j) prevent Processing that is likely to cause
damage or distress to the Data Subject or anyone else;
(k) be notified of a Personal Data Breach which is
likely to result in high risk to their rights and freedoms;
(l) make a complaint to the supervisory authority;
(m) in
limited circumstances, receive or ask for their Personal Data to be transferred
to a third party in a structured, commonly used and machine-readable format;
and
You must verify the identity
of an individual requesting data under any of the rights listed above (do not
allow third parties to persuade you into disclosing Personal Data without
proper authorisation).
You must immediately forward
any Data Subject request you receive to your line manager and the DPO.
16.
Accountability
The Controller must implement
appropriate technical and organisational measures in an effective manner, to
ensure compliance with data protection principles. The Controller is
responsible for, and must be able to demonstrate, compliance with the data
protection principles.
The Company must have adequate
resources and controls in place to ensure and to document UK GDPR compliance
including:
(a) appointing a suitably qualified DPO (where
necessary) and an executive accountable for data privacy;
(b) implementing Privacy by Design when Processing
Personal Data and completing DPIAs where Processing presents a high risk to
rights and freedoms of Data Subjects;
(c) integrating data protection into internal
documents including this Data Protection Policy, Related Policies, Privacy
Guidelines or Privacy Notices;
(d) regularly training Company Personnel on the UK
GDPR, this Data Protection Policy, Related Policies and Privacy Guidelines and
data protection matters including, for example, Data Subject's rights, Consent,
legal basis, DPIA and Personal Data Breaches. The Company must maintain a
record of training attendance by Company Personnel; and
(e) regularly testing the privacy measures
implemented and conducting periodic reviews and audits to assess compliance, including
using results of testing to demonstrate compliance improvement effort.
17.
Record keeping
The UK GDPR requires us to keep full and accurate records
of all our data Processing activities.
You must keep and maintain accurate corporate records
reflecting our Processing including records of Data Subjects' Consents and
procedures for obtaining Consents [in accordance with the Company's
record-keeping guidelines].
These records should include, at a minimum, the name and
contact details of the Controller and the DPO, clear descriptions of the
Personal Data types, Data Subject types, Processing activities, Processing
purposes, third-party recipients of the Personal Data, Personal Data storage
locations, Personal Data transfers, the Personal Data's retention period and a
description of the security measures in place. To create the records, data maps
should be created which should include the detail set out above together with
appropriate data flows.
18.
Training and audit
We are required to ensure all Company Personnel have
undergone adequate training to enable them to comply with data privacy laws. We
must also regularly test our systems and processes to assess compliance.
You must undergo all mandatory data privacy related
training and ensure your team undergo similar mandatory training [in accordance
with the Company's mandatory training guidelines].
You must regularly review all the systems and processes
under your control to ensure they comply with this Data Protection Policy and
check that adequate governance controls and resources are in place to ensure
proper use and protection of Personal Data.
19.
Privacy by Design and
Data Protection Impact Assessment (DPIA)
We are required to implement Privacy by Design measures
when Processing Personal Data by implementing appropriate technical and
organisational measures (like Pseudonymisation) in an effective manner, to
ensure compliance with data privacy principles.
You must assess what Privacy by Design measures can be
implemented on all programmes, systems or processes that Process Personal Data
by taking into account the following:
·
the state of the art;
·
the cost of implementation;
·
the nature, scope, context and purposes of
Processing; and
·
the risks of varying likelihood and severity for
rights and freedoms of Data Subjects posed by the Processing.
Controllers must also conduct DPIAs in respect to high-risk
Processing.
You should conduct a DPIA (and discuss your findings with
the DPO) when implementing major system or business change programs involving
the Processing of Personal Data including:
·
use of new technologies (programs, systems or
processes), or changing technologies (programs, systems or processes);
·
Automated Processing including profiling and
ADM;
·
large-scale Processing of Special Categories of
Personal Data or Criminal Convictions Data; and
·
large-scale, systematic monitoring of a publicly
accessible area.
A DPIA must include:
·
a description of the Processing, its purposes
and the Controller's legitimate interests if appropriate;
·
an assessment of the necessity and proportionality
of the Processing in relation to its purpose;
·
an assessment of the risk to individuals; and
·
the risk mitigation measures in place and
demonstration of compliance.
20.
Automated Processing
(including profiling) and Automated Decision-Making
Generally, ADM is prohibited
when a decision has a legal or similar significant effect on an individual
unless:
(a) a data subject has explicitly consented
(b) the Processing is authorised by law; or
(c) the Processing is necessary for the performance of or entering into a contract.
If certain types of Special Categories of Personal Data
or Criminal Convictions Data are being processed, then grounds (b) or (c) will
not be allowed but the Special Categories of Personal Data and Criminal
Convictions Data can be Processed where it is necessary (unless less intrusive
means can be used) for substantial public interest like fraud prevention.
If a decision is to be based solely on Automated
Processing (including profiling), then Data Subjects must be informed when you
first communicate with them of their right to object. This right must be
explicitly brought to their attention and presented clearly and separately from
other information. Further, suitable measures must be put in place to safeguard
the Data Subject's rights and freedoms and legitimate interests.
We must also inform the Data Subject of the logic
involved in the decision making or profiling, the significance and envisaged
consequences and give the Data Subject the right to request human intervention,
express their point of view or challenge the decision.
A DPIA must be carried out before any Automated Processing
(including profiling) or ADM activities are undertaken.
21.
Direct marketing
We are subject to certain rules and privacy laws when
marketing to our customers.
For example, a Data Subject's prior consent is required for
electronic direct marketing (for example, by email, text or automated calls).
The limited exception for existing customers known as "soft opt-in"
allows organisations to send marketing texts or emails if they have obtained
contact details in the course of a sale to that person, they are marketing
similar products or services, and they gave the person an opportunity to opt
out of marketing when first collecting the details and in every subsequent message.
The right to object to direct marketing must be explicitly
offered to the Data Subject in an intelligible manner so that it is clearly
distinguishable from other information.
A Data Subject's objection to direct marketing must be promptly
honoured. If a customer opts out at any time, their details should be
suppressed as soon as possible. Suppression involves retaining just enough
information to ensure that marketing preferences are respected in the future.
22.
Sharing Personal Data
Generally we are not allowed to share Personal Data with third
parties unless certain safeguards and contractual arrangements have been put in
place.
You may only share the Personal Data we hold with another
employee, agent or representative of our group (which includes our subsidiaries
and our ultimate holding company along with its subsidiaries) if the recipient
has a job-related need to know the information and the transfer complies with
any applicable cross-border transfer restrictions.
You may only share the Personal Data we hold with third parties, such as our service providers, if
(a) they have a need to know the information for the
purposes of providing the contracted services;
(b) sharing the Personal Data complies with the
Privacy Notice provided to the Data Subject and, if required, the Data
Subject's Consent has been obtained;
(c) the third party has agreed to comply with the
required data security standards, policies and procedures and put adequate
security measures in place;
(d) the transfer complies with any applicable
cross-border transfer restrictions; and
(e) a fully executed written contract that contains
UK GDPR-approved third party clauses has been obtained.
23.
Changes
to this Data Protection Policy
We keep this Data Protection
Policy under regular review.
This Data Protection Policy
does not override any applicable national data privacy laws and regulations in
countries where the Company operates.