Data Protection Policy

1. Introduction

This Policy sets out the obligations of Locke Data Ltd (“the Company”) with regard to data protection and the rights of website users, customers, business contacts etc. (“data subjects”) in respect of their personal data under the Data Protection Act 1998 (“the Act”). Under the Act, “personal data” is defined as data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller (the Company in this context), and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.

This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures 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 a high premium 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.

The Company is registered with the Information Commissioner as a data controller under the register held by the Information Commissioner pursuant to Section 19 of the Act.

2. The Data Protection Principles

This Policy aims to ensure compliance with the Act. The Act sets out eight principles with which any party handling personal data must comply. All personal data:

2.1 Must be processed fairly and lawfully, meaning that at least one of the following conditions must be met:

2.2 Where the personal data is sensitive personal data (defined below in Part 4 of this Policy), at least one of the following conditions must be met:

2.3 Must be obtained only for specified and lawful purposes and shall not be processed in any manner which is incompatible with those purposes;

2.4 Must be adequate, relevant and not excessive with respect to the purposes for which it is processed;

2.5 Must be accurate and, where appropriate, kept up to date;

2.6 Must be kept for no longer than is necessary in light of the purpose(s) for which it is processed;

2.7 Must be processed in accordance with the rights of data subjects under the Act (for which, see Part 3 of this Policy);

2.8 Must be protected against unauthorised or unlawful processing, accidental loss, destruction or damage through appropriate technical and organisational measures; and

2.9 Must not be transferred to a country or territory outside of the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

3. Rights of Data Subjects

Under the Act, data subjects have the following rights:

4. Personal Data

Personal data is defined by the Act as data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.

The Act also defines “sensitive personal data” as personal data relating to the racial or ethnic origin of the data subject; their political opinions; their religious (or similar) beliefs; trade union membership; their physical or mental health condition; their sexual life; the commission or alleged commission by them of any offence; or any proceedings for any offence committed or alleged to have been committed by them, the disposal of such proceedings or the sentence of any court in such proceedings.

The Company only holds personal data that is directly relevant to its dealings with a given data subject. That data will be collected, held, and processed in accordance with the data protection principles and with this Policy. The following data may be collected, held and processed by the Company:

5. Processing Personal Data

Any and all personal data collected by the Company (as detailed in Part 4 of this Policy) is collected in order to ensure that the Company can provide the best possible service to its customers, and can work effectively with its partners, associates and affiliates and efficiently manage its employees, contractors, agents and consultants. The Company may also use personal data in meeting certain obligations imposed by law.

Certain data collected by the Company, such as IP addresses, certain information gathered by cookies, pseudonyms and other non-identifying information will nonetheless be collected, held and processed to the same standards as personal data.

Personal data may be disclosed within the Company, provided such disclosure complies with this Policy. Personal data may be passed from one department to another in accordance with the data protection principles and this Policy. Under no circumstances will personal data be passed to any department or any individual within the Company that does not reasonably require access to that personal data with respect to the purpose(s) for which it was collected and is being processed.

In particular, the Company shall ensure that:

6. Data Protection Procedures

The Company shall ensure that all of its employees, agents, contractors, or other parties working on behalf of the Company comply with the following when working with personal data:

7. Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding and processing of personal data:

8. Access by Data Subjects

A data subject may make a subject access request (“SAR”) at any time to find out more about the information which the Company holds about them.

Upon receipt of a SAR the Company shall have a maximum period of 40 calendar days within which to respond fully, but shall always aim to acknowledge receipt of SARs within 5 business days. The following information will be provided to the data subject:

9. Notification to the Information Commissioner’s Office

As a data controller, the Company is required to notify the Information Commissioner’s Office that it is processing personal data. The Company is registered in the register of data controllers, registration number: <>.

Data controllers must renew their notification with the Information Commissioner’s Office on an annual basis. Failure to notify constitutes a criminal offence.

Any changes to the register must be notified to the Information Commissioner’s Office within 28 days of taking place.

The Data Protection Officer shall be responsible for notifying and updating the Information Commissioner’s Office.

10. Implementation of Policy

This Policy shall be deemed effective as of August 30th, 2017. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.