Data Protection Policy

Introduction

The EU’s General Data Protection Regulation (GDPR) was introduced to unify all EU member states’ approaches to data regulation, ensuring all data protection laws are applied identically in every country within the EU. It will protect EU citizens from organisations using their data irresponsibly and puts them in charge of what information is shared, where and how it is shared.

Policy

The purpose of this Policy is to outline the commitment to compliance with the General Data Protection Regulation, by Churchill Specialist Contracting Limited (the “Company”).

Application

  • The GDPR applies to ‘controllers’ and ‘processors’. The Company is both a data controller and data processor.
  • A controller determines the purposes and means of processing personal data.
  • A processor is responsible for processing personal data on behalf of a controller.
  • A data processor under the GDPR is required to meet specific legal obligations including the requirement to maintain records of personal data and processing activities. Data processors have legal liability if found to be responsible for a breach.
  • Data controllers are not relieved of obligations where a processor is involved. The GDPR places further obligations on data controllers to ensure that contracts with data processors comply with the GDPR.
  • The GDPR applies to processing carried out by organisations operating within the EU. It also applies to organisations outside the EU that offer goods, or services to individuals in the EU.
  • The GDPR does not apply to certain activities including processing covered by the Law Enforcement Directive, processing for national security purposes and processing carried out by individuals purely for personal/household activities.

The Company is committed to compliance with the GDPR in so far that all data will be:

  • Processed lawfully, fairly and in a transparent manner in relation to individuals.
  • Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes, 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, or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
  • 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 Directors are committed to achieving compliance with the GDPR and are responsible for establishing, developing, and providing the appropriate resources and training in all areas of Company activities that involve the use of both personal and sensitive data. The Chief Executive Officer (CEO) has ultimate responsibility for data protection and to whom any reference should be made in any difficulty arising in the implementation of this policy.

 This Policy will be reviewed annually to ensure its continuing suitability, adequacy, effectiveness in its compliance with GDPR.