Data Protection Policy

Introduction

This document sets out the obligations of Couno Limited ("the Company") with regard to data protection and the rights of people with whom it works in respect of their personal data under the Data Protection Act 1998 ("the Act").
This Policy shall set out procedures which are to be followed when dealing with personal data. The procedures set out herein must be followed by the Company, its employees, contractors, agents, consultants, partners or other parties working on behalf of the Company.
The Company views the correct and lawful handling of personal data as key to its success and dealings with third parties. The Company shall ensure that it handles all personal data correctly and lawfully.

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:

Rights of Data Subjects

Under the Act, data subjects have the following rights:

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 which is directly relevant to its dealings with a given data subject. That data will be 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 from time to time:

Processing Personal Data

Any and all personal data collected by the Company (including that detailed in Section 4 of this Policy) is collected in order to ensure that the Company can facilitate efficient transactions with third parties including, but not limited to, its customers, partners, associates and affiliates and efficiently manage its employees, contractors, agents and consultants. Personal data shall also be used by the Company in meeting any and all relevant obligations imposed by law.
Personal data may be disclosed within the Company. 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.
The Company shall ensure that:

Data Protection Procedures

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

Organisational Measures

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

Access by Data Subjects

A data subject may make a subject access request ("SAR") at any time to see the information which the Company holds about them.

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.
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 Designated Officer shall be responsible for notifying and updating the Information Commissioner's Office.

Implementation of Policy

This Policy shall be deemed effective as of September 2015 No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.