Data Protection Policy

1st August 2026

Introduction

This Policy sets out the obligations of Glentee Publishing, Ground Floor, Gallery Building, 65-69 Dublin Road, Belfast. BT2 7HG GB, regarding data protection and the rights of data subjects, e.g. staff, customers, business contacts etc. in respect of their personal data under UK Data Protection Legislation (defined below).

This Policy sets out this business'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 this business, its employees, agents, contractors, or other parties working on behalf of Glentee Publishing.

Definitions

“automated decision-making” means the making of a decision by automated means without meaningful human involvement;

“consent” means the consent of the data subject which must be a freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they (by a statement or by a clear affirmative action) signify their agreement to the processing of personal data relating to them;

“data controller” means the person or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data. For this Policy, the company is the data controller of all personal data relating to data subjects, e.g. staff, customers, business contacts etc. used in our business;

“data processor” means a person or organisation which processes personal data on behalf of a data controller;

“Data Protection Lead” means the person appointed by the Company to oversee data protection compliance where the Company is not required to appoint a statutory Data Protection Officer;

“Data Protection Legislation” means all applicable legislation in force from time to time in the United Kingdom applicable to data protection and privacy including, but not limited to, the UK GDPR, the Data Protection Act 2018 (and regulations made thereunder), and the Privacy and Electronic Communications Regulations 2003 as amended, and any successor legislation;

“data subject” means a living, identified, or identifiable individual about whom the Company holds personal data;

“EEA” means the European Economic Area, consisting of all EU Member States, Iceland, Liechtenstein, and Norway;

“personal data” means any information relating to a data subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, 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 data subject;

“personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed;

“processing” means any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person; and

“special category personal data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sexual life, sexual orientation, biometric, or genetic data.

Data Protection Officer & Scope of Policy

The Company’s Data Protection Officer is Alice Mac, [email protected]. The Data Protection Officer is responsible for administering this Policy and for developing and implementing any applicable related policies (including those referred to in this Policy), procedures, and/or guidelines.

All managers are responsible for ensuring that all employees, agents, contractors, or other parties working on behalf of the Company comply with this Policy and, where applicable, must implement such practices, processes, controls, and training as are reasonably necessary to ensure such compliance.

Any questions relating to this Policy, the Company’s collection, processing, or holding of personal data, or to Data Protection Legislation should be referred to the Data Protection Officer.

The Data Protection Principles

The Data Protection Legislation sets out the following principles with which any party handling personal data must comply. All personal data must be:

processed lawfully, fairly, and in a transparent manner in relation to the data subject;

collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing must be assessed in accordance with Part 9 of this Policy. Further processing for archiving purposes in the public interest, scientific or historical research purposes (including qualifying commercial scientific research where permitted by Data Protection Legislation), or statistical purposes shall not be considered to be incompatible with the initial purposes;

adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;

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;

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 (including qualifying commercial scientific research where permitted by Data Protection Legislation), or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the Data Protection Legislation in order to safeguard the rights and freedoms of the data subject;

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.

The Rights of Data Subjects

The Data Protection Legislation sets out the following key rights applicable to data subjects:

The right to be informed;

the right of access;

the right to rectification;

the right to erasure (also known as the ‘right to be forgotten’);

the right to restrict processing;

the right to data portability;

the right to object; and

rights with respect to automated decision-making and profiling.

Lawful, Fair, and Transparent Data Processing

The Data Protection Legislation seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. Specifically, the processing of personal data shall be lawful if at least one of the following applies:

the data subject has given consent to the processing of their personal data for one or more specific purposes;

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;

the processing is necessary for compliance with a legal obligation to which the data controller is subject;

the processing is necessary to protect the vital interests of the data subject or of another natural person;

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. (This lawful basis will not usually apply to private businesses unless they are carrying out a task in the public interest or exercising official authority under the law);

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; or

where permitted by Data Protection Legislation, the Company may rely on a recognised legitimate interest. Recognised legitimate interests are limited to specific purposes set out in Data Protection Legislation and should not be treated as a general replacement for the ordinary legitimate interests lawful basis. Where the Company relies on a recognised legitimate interest, it shall record the relevant recognised legitimate interest and ensure that the processing is necessary for that purpose.

If the personal data in question is special category personal data (also known as ‘sensitive personal data’), at least one of the following conditions must be met. Note that not all of the conditions listed below will be available to all organisations. In particular, conditions relating to public interest, public health, archiving in the public interest, or official functions should only be relied upon where they are applicable to the Company’s activities and supported by Data Protection Legislation:

the data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless the law prohibits them from doing so);

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 law or a collective agreement pursuant to law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);

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;

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;

the processing relates to personal data which is manifestly made public by the data subject;

the processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;

the processing is necessary for substantial public interest reasons, on the basis of 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;

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 law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the UK GDPR;

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 law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or

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 UK GDPR (as supplemented by section 19 of the Data Protection Act 2018) based on 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.]

Consent

If consent is relied upon as the lawful basis for collecting, holding, and/or processing personal data, the following shall apply:

Consent is a clear indication by the data subject that they agree to the processing of their personal data. Such a clear indication may take the form of a statement or a positive action. Silence, pre-ticked boxes, or inactivity are unlikely to amount to consent.

Where consent is given in a document which includes other matters, the section dealing with consent must be kept clearly separate from such other matters.

Data subjects are free to withdraw consent at any time and it must be made easy for them to do so. If a data subject withdraws consent, their request must be honoured promptly.

If personal data is to be processed for a new purpose, the Company must assess whether the new purpose is compatible with the original purpose, whether Data Protection Legislation otherwise permits the new processing, and whether a new lawful basis or updated privacy information is required. Where the new processing relies on consent and the original consent does not cover the new purpose, fresh consent must be obtained.

[If special category personal data is processed, the Company shall normally rely on a lawful basis other than explicit consent. If explicit consent is relied upon, the data subject in question must be issued with a suitable privacy notice in order to capture their consent.]

In all cases where consent is relied upon as the lawful basis for collecting, holding, and/or processing personal data, records must be kept of all consents obtained in order to ensure that the Company can demonstrate its compliance with consent requirements.

Specified, Explicit, and Legitimate Purposes

The Company collects and processes the personal data as set out. This includes:

personal data collected directly from data subjects.

The Company only collects, processes, and holds personal data for the specific purposes set out as above.

Data subjects must be kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 16 for more information on keeping data subjects informed.

Further Processing

The Company shall not process personal data for a new purpose that is incompatible with the purpose or purposes for which it was originally collected unless the data subject has given valid consent or the processing is otherwise permitted by the Data Protection Legislation.

Before using personal data for a new purpose, the Company shall consider, where relevant:

any link between the original purpose and the new purpose;

the context in which the personal data was collected;

the nature of the personal data, including whether it includes special category personal data or criminal offence data;

the possible consequences of the new processing for data subjects; and

the existence of appropriate safeguards, including encryption or pseudonymisation, where appropriate.

Where the Data Protection Legislation specifies that certain further processing is compatible with the original purpose, the Company may rely on that provision where applicable, provided that the processing is documented and appropriate safeguards are applied.

Where personal data is to be used for a new purpose, the Company shall update any and all applicable privacy information as required.

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 Parts 8 and 9, above.

Employees, agents, contractors, or other parties working on behalf of the Company may collect personal data only to the extent required for the performance of their job duties and only in accordance with this Policy. Excessive personal data must not be collected.

Employees, agents, contractors, or other parties working on behalf of the Company may process personal data only when the performance of their job duties requires it. Personal data held by the Company cannot be processed for any unrelated reasons.

Accuracy of Data and Keeping Data Up-to-Date

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, as set out in Part 18, below.

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.

Data Retention

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.

When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.

For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.

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 the Company’s Data Security Policy.

All technical and organisational measures taken to protect personal data shall be regularly reviewed and evaluated to ensure their ongoing effectiveness and the continued security of personal data.

Data security must be maintained at all times by protecting the confidentiality, integrity, and availability of all personal data as follows:

only those with a genuine need to access and use personal data and who are authorised to do so may access and use it;

personal data must be accurate and suitable for the purpose or purposes for which it is collected, held, and processed; and

authorised users must always be able to access the personal data as required for the authorised purpose or purposes.

Accountability and Record-Keeping

The Data Protection Officer is responsible for administering this Policy and for developing and implementing any applicable related policies, procedures, and/or guidelines.

The Company shall follow a privacy by design approach at all times when collecting, holding, and processing personal data. Data Protection Impact Assessments shall be conducted if any processing is likely to result in a high risk to the rights and freedoms of data subjects (please refer to Part 15 for further information).

All employees, agents, contractors, or other parties working on behalf of the Company shall be given appropriate training in data protection and privacy, addressing the relevant aspects of the Data Protection Legislation, this Policy, and all other applicable Company policies.

The Company’s data protection compliance shall be regularly reviewed and evaluated by means of Data Protection Audits.

The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following:

the name and details of the Company, its Data Protection Officer, and any applicable third-party data transfers (including data processors and other data controllers with whom personal data is shared);

the purposes for which the Company collects, holds, and processes personal data;

the Company’s lawful basis or bases for collecting, holding, and processing personal data, including, where applicable, details of any consent relied upon, the mechanism(s) for obtaining such consent, and records of such consent, details of any ordinary legitimate interests relied upon and any legitimate interests assessment, and details of any recognised legitimate interest relied upon;

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;

details of any transfers of personal data to non-UK countries including all mechanisms and security safeguards;

details of how long personal data will be retained by the Company (please refer to the Company’s Data Retention Policy);

details of personal data storage, including location(s);

detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data;

where applicable, details of any further processing compatibility assessments; and

records of data protection complaints received, the steps taken to investigate and respond to them, and any remedial action taken.

Data Protection Impact Assessments and Privacy by Design

In accordance with privacy by design principles, 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 where the processing involved is likely to result in a high risk to the rights and freedoms of data subjects.

The principles of privacy by design should be followed at all times when collecting, holding, and processing personal data. The following factors should be taken into consideration:

the nature, scope, context, and purpose or purposes of the collection, holding, and processing;

the state of the art of all relevant technical and organisational measures to be taken;

the cost of implementing such measures; and

the risks posed to data subjects and to the Company, including their likelihood and severity.

Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:

the type(s) of personal data that will be collected, held, and processed;

the purpose(s) for which personal data is to be used;

the Company’s objectives;

how personal data is to be used;

the parties (internal and/or external) who are to be consulted;

the necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;

risks posed to data subjects;

risks posed both within and to the Company; and

proposed measures to minimise and handle identified risks.

The Company shall provide the information set out in Part 16.2 to every data subject:

where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and

where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:

if the personal data is used to communicate with the data subject, when the first communication is made; or

if the personal data is to be transferred to another party, before that transfer is made; or

as soon as reasonably possible and in any event not more than one month after the personal data is obtained.

The following information shall be provided in the form of a privacy notice:

details of the Company including, but not limited to, contact details, and the names and contact details of any applicable representatives and its Data Protection Officer;

the purpose(s) for which the personal data is being collected and will be processed (as detailed in <<insert location(s)>>) and the lawful basis justifying that collection and processing;

where processing is based on the legitimate interests lawful basis, details of the legitimate interests relied upon by the Company or by a third party, and where processing is based on recognised legitimate interests, details of the recognised legitimate interest relied upon;

where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;

where the personal data is to be transferred to one or more third parties, details of those parties;

where the personal data is to be transferred to a third party that is located outside of the UK, details of that transfer, including but not limited to the safeguards in place (see Part 26 of this Policy for further details);

details of applicable data retention periods;

details of the data subject’s rights under the Data Protection Legislation;

details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;

details of how the data subject can raise a data protection complaint with the Company, including how such a complaint can be submitted electronically, and details of the data subject’s right to complain to the Information Commissioner’s Office;

where the personal data is not obtained directly from the data subject, details about the source of that personal data;

where 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

where applicable, details of any solely automated decision-making, including profiling, that will have legal or similarly significant effects on data subjects, meaningful information about the logic involved, the significance and envisaged consequences of such processing, and the safeguards available to data subjects.

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.

When responding to a SAR, the Company shall carry out reasonable and proportionate searches for the personal data requested, taking into account the nature of the request, the personal data likely to be held, the systems and records used by the Company, and the effort involved in locating the relevant personal data.

If the Company reasonably requires clarification in order to respond to a SAR, it may request clarification from the data subject. Where permitted by Data Protection Legislation, the time limit for responding to the SAR shall be paused until the data subject provides the clarification requested. The Company shall only request clarification where it is reasonably necessary and shall record the request, the reason for it, and the date on which clarification is received.

Responses to SARs must 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.

All SARs received shall be handled by the Data Protection Officer

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.

Rectification of Personal Data

Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.

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.

If 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.

Erasure of Personal Data

Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

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;

the data subject wishes to withdraw their consent to the Company holding and processing their personal data;

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) (see Part 22 of this Policy for further details concerning the right to object);

the personal data has been processed unlawfully;

the personal data needs to be erased in order for the Company to comply with a particular legal obligation;

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 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.

In the event that any personal data that is to be erased in response to a data subject’s request 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).

Restriction of Personal Data Processing

Data subjects may request that the Company cease 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.

If 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)

Objections to Personal Data Processing

Data subjects have the right to object to the Company processing their personal data based on ordinary legitimate interests, for direct marketing (including profiling).

Where a data subject objects to the Company processing their personal data based on ordinary legitimate interests, the Company shall cease such processing immediately, unless it can demonstrate compelling legitimate grounds for such processing which override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the establishment, exercise, or defence of legal claims.

Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing promptly.

Direct Marketing

The Company is subject to certain rules and regulations when marketing its products and services.

The prior consent of data subjects is required for electronic direct marketing including email, text messaging, and automated telephone calls subject to the following limited exception:

The Company may send marketing text messages or emails to a customer provided that that customer’s contact details have been obtained in the course of a sale, the marketing relates to similar products or services, and the customer has been given the opportunity to opt-out of marketing when their details were first collected and in every subsequent communication from the Company.

The Company shall comply with Data Protection Legislation when carrying out direct marketing and when using cookies, pixels, tracking technologies, or similar storage and access technologies.

The right to object to direct marketing shall be explicitly offered to data subjects in a clear and intelligible manner and must be kept separate from other information in order to preserve its clarity.

If a data subject objects to direct marketing, their request must be complied with promptly. A limited amount of personal data may be retained in such circumstances to the extent required to ensure that the data subject’s marketing preferences continue to be complied with.

Personal Data Collected, Held, and Processed

Full details of the personal data collected, held, and processed by the Company. For details of data retention, please refer to the Company’s Data Retention Policy.

Transferring Personal Data to a Country Outside the UK

The Company may, from time to time, transfer personal data, including by making it available remotely, to countries or organisations outside of the UK. The Company shall only do so where Data Protection Legislation permits the transfer and where the level of protection for data subjects is not undermined.

Personal data may only be transferred to a country outside the UK if one of the following applies:

The UK has issued adequacy regulations confirming that the personal data will receive an adequate level of protection (referred to as ‘adequacy decisions’, ‘adequacy regulations’, or ‘partial findings of adequacy’). Such regulations may apply to a country as a whole, organisation(s), framework(s) or mechanism(s), or to data covered by specific legislation. Since 1 January 2021, transfers of personal data from the UK to EEA countries have continued to be permitted. Pre-existing EU Commission adequacy decisions in effect as at 31 December 2020 are also recognised, subject to ongoing review by the UK Government.

Appropriate safeguards are in place including binding corporate rules, standard contractual clauses approved for use in the UK, an approved code of conduct, or an approved certification mechanism. Standard contractual clauses include the International Data Transfer Agreement issued by the Information Commissioner’s Office and the International Data Transfer Addendum to the current EU Commission Standard Contractual Clauses (set out in the Annex of Commission Implementing Decision (EU) 2021/914 of 4 June 2021), issued by the Information Commissioner’s Office. Where appropriate safeguards are relied upon, the Company shall carry out and document any transfer risk assessment required by Data Protection Legislation, taking into account whether the standard of protection for the personal data will be materially lower than that provided under UK Data Protection Legislation.

The transfer is made with the informed and explicit consent of the relevant data subject(s).

The transfer is necessary for one of the other reasons set out in the UK GDPR including the performance of a contract between the data subject and the Company; public interest reasons; for the establishment, exercise, or defence of legal claims; to protect the vital interests of the data subject where the data subject is physically or legally incapable of giving consent; or, in limited circumstances, for the Company’s legitimate interests.

Data Protection Complaints

Data subjects may submit complaints about the Company’s handling of their personal data or compliance with Data Protection Legislation by contacting [email protected]

The Company shall take appropriate steps to make it easy for data subjects to submit data protection complaints, including by electronic means.

The Company shall acknowledge receipt of a data protection complaint within 30 days of receipt.

The Company shall consider the complaint without undue delay and shall provide a response to the complainant within a reasonable period.

If the Company requires further information in order to investigate the complaint, it shall request that information promptly.

The Company shall keep records of data protection complaints received, the steps taken to investigate them, the outcome, and any remedial action taken.

Data subjects remain entitled to complain to the Information Commissioner’s Office.

Data Breach Notification

All personal data breaches must be reported immediately to the Company’s Data Protection Officer.

If an employee, agent, contractor, or other party working on behalf of the Company becomes aware of or suspects that a personal data breach has occurred, they must not attempt to investigate it themselves. Any and all evidence relating to the personal data breach in question should be carefully retained.

If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.

In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 28.3) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.

Data breach notifications shall include the following information:

The categories and approximate number of data subjects concerned;

The categories and approximate number of personal data records concerned;

The name and contact details of the Company’s Data Protection Officer (or other contact point where more information can be obtained);

The likely consequences of the breach;

Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

Implementation of Policy

This Policy shall be deemed effective as of 1st August 2026. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

This Policy has been approved and authorised by:

Name: Alice Mac

Position:Business Owner

Date: 01/08/2026

Due for Review by: 01/08/2028

Signature: Alice Mac