KCIR Limited
Privacy Standard
Your data is important to us as is the data of our customers and
suppliers. We are all responsible for
ensuring compliance with this policy. If
you are unsure about anything, just ask, it is better to ask the question if
you are unsure. We would rather you did
that than take the risk which could have criminal consequences.
There are many
definitions used throughout this policy, please take the time to familiarise
yourself with these
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 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: KCIR 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 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 Contact (DPC): we are not required to appoint a
mandatory Data Protection Officer under the GDPR. As such, we have a nominated
contact who deals with queries relating to Data protection and GDPR.
EEA: the 28 countries in the EU, and Iceland, Liechtenstein and
Norway.
Explicit Consent: consent which requires a very clear and specific statement
(that is, not just action).
General Data Protection Regulation (GDPR): the General Data Protection
Regulation ((EU) 2016/679). Personal Data is subject to the legal
safeguards specified in the 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 GDPR.
Privacy Guidelines: the Company privacy and GDPR related guidelines provided to
assist in interpreting and implementing this Privacy Standard and Related
Policies, available in the Company Handbook or upon request.
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.
Related Policies: the Company’s policies, operating procedures or processes
related to this Privacy Standard and designed to protect Personal Data,
available in the Company Handbook or upon request.
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 Privacy Standard sets out how KCIR Limited (”we”,
“our”, “us”, “the Company”) handle the Personal Data of our customers,
suppliers, employees, workers and other third parties that we may work with or alongside.
This Privacy Standard 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 Privacy Standard applies to all Company Personnel (”you”,
“your”). You must read, understand and comply with this Privacy Standard when
Processing Personal Data on our behalf and attend training on its requirements.
This Privacy Standard sets out what we expect from you for the Company to
comply with applicable law. Your compliance with this Privacy Standard is
mandatory. Related Policies and Privacy Guidelines are available to help you
interpret and act in accordance with this Privacy Standard. You must also
comply with all such Related Policies and Privacy Guidelines. Any breach of
this Privacy Standard may result in disciplinary action being taken against you.
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 Privacy Standard or otherwise then you
must comply with the Related Policies and Privacy Guidelines.
This Privacy Standard (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 DPC.
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 €20 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 GDPR. Hence the importance of complying with this
policy.
All Directors, Managers and Supervisors are responsible for
ensuring that all Company Personnel comply with this Privacy Standard and need
to implement appropriate practices, processes, controls and training to ensure
that compliance.
The DPC is responsible for overseeing this Privacy Standard and, as applicable, developing any Related Policies and Privacy Guidelines. The DPC can be emailed at info@kingcharlesireturn.co.uk.
Please contact the DPC with any questions about the operation of
this Privacy Standard or the GDPR or if you have any concerns that this Privacy
Standard is not being or has not been followed. In particular, you must always
contact the DPC 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 EEA (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 GDPR which require Personal Data to be:
(a) Processed lawfully, fairly and in a transparent manner
(commonly known as “Lawfulness, Fairness and Transparency”);
(b) collected only for specified, explicit and legitimate
purposes (commonly known as “Purpose Limitation”);
(c) adequate, relevant and limited to what is necessary in
relation to the purposes for which it is Processed (commonly known as “Data
Minimisation”);
(d) accurate and where necessary kept up to date (commonly
known as “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 (commonly known as “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 (commonly known as “Security, Integrity and Confidentiality”);
(g) not transferred to another country without appropriate
safeguards being in place (commonly known as “Transfer Limitation”); and
(h) made available to Data Subjects and allows Data
Subjects to exercise certain rights in relation to their Personal Data (commonly
known as “Data Subject’s Rights and Requests”).
We are responsible for and must be able to demonstrate compliance
with the data protection principles listed above (commonly known as “Accountability”). We generally do not send information outside
of the UK and so paragraph 4(g) does not necessarily apply, however it is worth
noting if nothing else.
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 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 affecting the Data Subject in an adverse manner.
The 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; or
(e) to pursue our legitimate interests 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.
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 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 an affirmative action so silence, pre-ticked boxes
or inactivity are unlikely to be sufficient to prove consent was given. 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 by us. 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 provided
their consent.
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 GDPR requires Data 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 human resources or employment purposes, we must provide the Data
Subject with all the information required by the GDPR including the identity of
the Controller and DPC, 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 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 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.
If we do not have a Privacy Notice for that specific purpose, then
please inform the DPC so you can be provided with one.
8. PURPOSE LIMITATION
Personal Data must be collected only for specified, explicit and
legitimate purposes. It must not be Processed further in any manner
incompatible or inconsistent 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 provided their
Consent 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 of Processing.
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, we would suggest at the very
least once every 12 months. 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).
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.
You must comply with and not attempt to circumvent the
administrative, physical and technical safeguards we implement and maintain in
accordance with the GDPR and relevant standards to protect Personal Data.
13. REPORTING A PERSONAL DATA BREACH
The GDPR requires Controllers to notify any Personal Data Breach
to the applicable regulator 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 DPC.
You should preserve all evidence relating to the potential Personal Data
Breach.
14. TRANSFER LIMITATION
The GDPR restricts data transfers to countries outside the EEA to
ensure that the level of data protection afforded to individuals by the 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 EEA if one of the following
conditions applies:
(a) the European Commission has issued a decision
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 by the European
Commission, an approved code of conduct or a certification mechanism, a copy of
which can be obtained from the DPC;
(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 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 Data
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 EEA;
(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; and
(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.
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 the DPC.
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 GDPR compliance.
17. RECORD KEEPING
The 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.
These records should include, at a minimum, the name and contact
details of the Controller and the DPC, 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.
You must regularly review all the systems and processes under your
control to ensure they comply with this Privacy Standard 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.
If necessary, Data
controllers must also conduct DPIAs in respect to high-risk Processing.
You should conduct a DPIA (and discuss your findings with the DPC)
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 Data
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
GDPR-approved third party clauses has been obtained.
23. CHANGES TO THIS PRIVACY STANDARD
We keep this Privacy Standard under regular review.
This Privacy Standard does not override any applicable national
data privacy laws and regulations in countries where the Company operates.