CKB Ltd

Data Protection Policy

December 2024

1. Introduction
This Policy sets out the obligations of CKB Ltd ® and its group brands including Lanyards Tomorrow ® ,Gifts Tomorrow ™ and Bar Amigos ® (“the Company”), a Company registered in England under 07123102 (VAT number 991324508), whose registered address is St. Christopher’s House, Ridge Road, Letchworth Garden City, Hertfordshire, SG6 1PT, England and whose main trading address is Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS, regarding data protection and the rights of its customers (website users), business contacts, contractors, etc., together known as “data subjects” in respect of their personal data under data protection legislation including The UK Data Protection Act 2018 and UK-GDPR (General Data Protection Regulation).
The UK-GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an 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 natural person which is in the possession of, or is likely to come into the possession of the data controller (the Company in this context).
This Policy sets the Company’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 the Company. The Company must satisfy itself that any parties working on behalf of the Company deal with personal data appropriately.
The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance 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. As such, the Company has analysed Our Site including its appeal in respect of the Age-Appropriate Design Code 2020.

2. Definitions

3. The Data Protection Principles
This Policy aims to ensure compliance with the UK-GDPR. The UK-GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:
3.1 Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
3.2 Collected for specified, explicit, and legitimate purposes and not be 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.
3.3 Adequate, relevant, and limited to what is necessary in relation to the purposes
for which it is processed.
3.4 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.
3.5 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 UK-GDPR in order to safeguard the rights and freedoms of the data subject.
3.6 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.

4. The Rights of Data Subjects
One of the key rights of data subjects in the UK-GDPR is the right to object to how their data is processed based on legitimate interests and direct marketing (including profiling). Please refer to Parts 20-22 for more information. The Company undertakes no direct e-mail, postal or telephone marketing activity to promote products, etc., to individual customers. It may, however, undertake marketing activity to promote products to businesses based on Our legitimate interests and in accordance with Our marketing strategy.
4.1 The right to be informed (Part 14).
4.2 The right of access (Part 15;
4.3 The right to rectification (Part 16;
4.4 The right to erasure (also known as the ‘right to be forgotten’) (Part 17);
4.5 The right to restrict processing (Part 18);
4.6 The right to data portability (Part 19);
4.7 The right to object (Part 20); and
4.8 Rights with respect to automated decision-making and profiling (Parts 21 and 22).

5. Lawful, Fair, and Transparent Data Processing
5.1 The UK-GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The UK-GDPR states that processing of personal data shall be lawful if at least one of the following applies:
5.1.1 The data subject has given consent to the processing of their personal data for one or more specific purposes;
5.1.2 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 with them;
5.1.3 The processing is necessary for compliance with a legal obligation to which the data controller is subject;
5.1.4 The processing is necessary to protect the vital interests of the data subject or of another natural person;
5.1.5 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; or
5.1.6 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.
Please refer to the CKB Ltd ® Website Privacy & Cookies Policy/ Wholesale Gifts Tomorrow Website Privacy & Cookies Policy for more information on the lawful basis for the Company’s data processing activities.
5.2 The Company does not process “special category data” (also known as “sensitive personal data”) on its website as defined under the UK-GDPR. “Special category data” includes, for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation. Employees of the Company should refer to the applicable Employee Data Protection Policy.
5.3 Whilst supporting transparency, The Company also needs to be mindful of its requirement to protect its business knowledge and security. Should a data subject wish to enquire further about details of third parties the Company works with, etc., please contact the Data Protection Officer at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Herts, SG6 2TS.

6. Consent
If consent is relied upon as the lawful basis for collecting, holding, and/or processing any personal data, the following shall apply:
6.1 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.
6.2 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.
6.3 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.
6.4 If personal data is to be processed for a different purpose that is incompatible with the purpose or purposes for which that personal data was originally collected that was not disclosed to the data subject when they first provided their consent, consent to the new purpose or purposes may need to be obtained from the data subject.
6.5 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.
Please refer to the CKB Ltd ® Website Privacy & Cookies Policy/ Wholesale Gifts Tomorrow Website Privacy & Cookies Policy for further information on the Company’s data processing activities which rely on consent.

7. Specified, Explicit, and Legitimate Purposes
7.1 The Company collects and processes the personal data set out in Part 23 of this Policy. This includes:
7.1.1 Personal data collected directly from data subjects. This includes contact details used when a data subject communicates with the Company for the purpose of that communication / fulfilling an order; and
7.1.2 Personal data obtained from third parties. This includes contact details from marketplace portals where the Company also sells its products such as Amazon to fulfil orders. Please note that such marketplace portals will operate their own data protection and privacy policies.
7.2 The Company only collects, processes, and holds personal data for the specific purposes set out in Part 23 of this Policy (or for other purposes expressly permitted by the UK-GDPR).
7.3 Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 14 for more information on keeping data subjects informed.

8. Adequate, Relevant, and Limited Data Processing
8.1 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 Part 5, above, and as set out in Part 23, below.

9. Accuracy of Data and Keeping Data Up-to-Date
9.1 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 16, below.
9.2 The accuracy of personal data shall be checked when it is collected. The turnaround time from order receipt to order processing is not long and, as such, there is not an opportunity or requirement to re-check the data accuracy at another point in the future. Should a customer make contact about an order between receipt and processing, their request to alter the data provided will be fulfilled whenever possible (for example, altering the delivery address for a product). 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.

10. Data Retention
10.1 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.
10.2 When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
10.3 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.

11. Secure Processing
11.1 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 Parts 24 to 29 of this Policy.

12. Accountability and Record-Keeping
12.1 The Company’s Data Protection Officer is the position holder of Company Secretary, CKB Ltd, of Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS.
12.2 The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the UK-GDPR and other applicable data protection legislation.
The Data Protection Officer should be consulted about data protection matters including but not limited to the following cases:
12.2.1 if there is any uncertainty relating to the lawful basis on which personal data is to be collected, held, and/or processed;
12.2.2 if any new or amended privacy notices or similar privacy-related documentation is required;
12.2.3 if any assistance is required in dealing with the exercise of a data subject’s rights (including, but not limited to, the handling of subject access requests);
12.2.4 if a personal data breach (suspected or actual) has occurred;
12.2.5 if there is any uncertainty relating to security measures (whether technical or organisational) required to protect personal data;
12.2.6 if personal data is to be shared with third parties; and
12.2.7 when any significant new processing activity is to be carried out, or significant changes are to be made to existing processing activities, which will require a Data Protection Impact Assessment
12.3 The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
12.3.1 The name and details of the Company, its Data Protection Officer if available, and any applicable third-party data processors;
12.3.2 The purposes for which the Company collects, holds, and processes personal data;
12.3.3 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;
12.3.4 Details of any transfers of personal data to non-European Economic Area (“EEA”) countries including security safeguards (See Part 30 concerning the impact of Brexit);
12.3.5 Details of how long personal data will be retained by the Company (please refer to the Company’s Data Retention Policy); and
12.3.6 Descriptions of any technical and organisational measures taken as communicated by the Company to ensure the security of personal data (please refer to the Company Information Security Policy).
12.4 If you are in the European Union, you may address privacy-related inquiries to our EU Representative pursuant to Article 27 EU-GDPR:

EU-REP.Global GmbH
www.eu-rep.global
Attn: CKB Ltd.
Hopfenstr. 1d, 24114 Kiel, Germany
[email protected]

13. Data Protection Impact Assessments & Privacy by Design
13.1 In accordance with the ‘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 the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the UK-GDPR.
13.2 The principles of ‘privacy by design’ should be followed at all times when collecting, holding, and processing employee personal data. The following factors should be taken into consideration:
13.2.1 the nature, scope, context, and purpose or purposes of the collection, holding, and processing;
13.2.2 the state of the art of all relevant technical and organisational measures to be taken;
13.2.3 the cost of implementing such measures; and
13.2.4 the risks posed to employee data subjects and to the Company, including their likelihood and severity.
13.3 Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:
13.3.1 The type(s) of personal data that will be collected, held, and processed;
13.3.2 The purpose(s) for which personal data is to be used;
13.3.3 The Company’s objectives;
13.3.4 How personal data is to be used;
13.3.5 The parties (internal and/or external) who are to be consulted, if applicable;
13.3.6 The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
13.3.7 Risks posed to data subjects;
13.3.8 Risks posed both within and to the Company; and
13.3.9 Proposed measures to minimise and handle identified risks.

14. Keeping Data Subjects Informed
14.1 The Company shall provide the information set out in Part 14.2 to every data subject (n.b. please refer to the Company’s data protection/ UK-GDPR policies for this detail):
14.1.1 Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and
14.1.2 Where personal data is obtained from a third party (e.g. a marketplace site upon which its products are sold), the relevant data subjects should be informed of its purpose by the third party:
a) if the personal data is used to communicate with the data subject, when the first communication is made; or
b) if the personal data is to be transferred to another party, before that transfer is made; or
c) as soon as reasonably possible and in any event not more than one month after the personal data is obtained.
14.2 The following information shall be provided:
14.2.1 Details of the Company including, but not limited to, the identity of its Data Protection Officer if available;
14.2.2 The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 23 of this Policy) and the legal basis justifying that collection and processing;
14.2.3 Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
14.2.4 Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
14.2.5 Where the personal data is to be transferred to one or more third parties, details of those parties. Details of third parties are not listed here for reasons of the Company’s requirement to protect its business knowledge and security. Should a data subject wish to enquire further about details of third parties the Company works with, etc., please contact the Data Protection Officer at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Herts, SG6 2TS).
14.2.6 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 30 of this Policy for further details). Please also refer to Part 14.2.5 concerning the protection of business knowledge and security;
14.2.7 Details of data retention;
14.2.8 Details of the data subject’s rights under the UK-GDPR;
14.2.9 Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
14.2.10 Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the UK-GDPR);
14.2.11 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
14.2.12 Details of any automated decision-making or profiling that will take place by the Company using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

15. Data Subject Access
15.1 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.
15.2 Data subjects wishing to make a SAR may do so in writing, providing all necessary details. SARs should be addressed to the Company’s Data Protection Officer at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS.
15.3 Responses to SARs shall 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.
15.4 All SARs received shall be handled by the Company’s Data Protection Officer.
15.5 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.

16. Rectification of Personal Data
16.1 Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.
16.2 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.
16.3 In the event that 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.

17. Erasure of Personal Data
17.1 Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:
17.1.1 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;
17.1.2 The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
17.1.3 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 20 of this Policy for further details concerning the right to object);
17.1.4 The personal data has been processed unlawfully; or
17.1.5 The personal data needs to be erased in order for the Company to comply with a particular legal obligation.
17.2 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.
17.3 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).

18. Restriction of Personal Data Processing
18.1 Data subjects may request that the Company ceases 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. Historic records may be retained for certain reasons including legal and financial accounting.
18.2 In the event that 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).

19. Data Portability
19.1 The Company processes personal data using automated means. The Company processes customer orders electronically for despatch.
19.2 Where data subjects have given their consent to the Company to process their personal data in such a manner, or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the right, under the UK-GDPR, to request to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers).
19.3 To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the following format if requested:
19.3.1 Electronic details of orders placed within the data retention period if required.
19.4 It is not envisaged that order information would be requested to be issued to anyone other than the customer if requested. However, if requested by a data subject and if technically feasible, personal data shall be sent directly to the required data controller.
19.5 All requests for copies of personal data shall be complied with within one month of the data subject’s request. The period can be extended by up to two months in the case of complex or numerous requests. If such additional time is required, the data subject shall be informed.

20. Objections to Personal Data Processing (The Right to Object)
20.1 Data subjects have the right to object to the Company processing their personal data based on legitimate interests and direct marketing (including profiling).
20.2 Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.
20.3 Where a data subject objects to the Company processing their personal data for profiling purposes, the Company shall cease such processing immediately. The Company undertakes no direct e-mail, postal or telephone marketing activity to promote products, etc., to individual customers. It may, however, undertake marketing activity to promote products to businesses based on Our legitimate interests and in accordance with Our marketing strategy.
For more information relating to profiling activity please see Part 22.

21. Automated Decision-Making
21.1 The Company uses personal data in automated decision-making processes. Such automated decisions include the following on our transactional sites (1) the initial part of a customer’s IP address being used to determine which currency should be displayed on Our Site; (2) the customer’s postcode being used to determine the best courier to use; and (3) the weight of an item being used to determine the best delivery method for the customer’s order.
21.2 Where such decisions have a legal (or similarly significant effect) on data subjects, those data subjects have the right to challenge such decisions under the UK-GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.
21.3 The right described in Part 21.2 does not apply in the following circumstances:
21.3.1 The decision is necessary for the entry into, or performance of, a contract between the Company and the data subject;
21.3.2 The decision is authorised by law; or
21.3.3 The data subject has given their explicit consent.

22. Profiling
22.1 The Company uses personal data for profiling purposes. For example, the use of an IP address allows the Company to analyse behaviour on its website including where a visitor has come from on the internet and how long a visitor spends on each of the Company’s web pages. For more information on this please see Part 23 below and the CKB Ltd ® Website Privacy & Cookies Policy.
22.2 When personal data is used for profiling purposes, the following shall apply:
22.2.1 Clear information explaining the profiling shall be provided to data subjects, including the significance and likely consequences of the profiling;
22.2.2 Appropriate mathematical or statistical procedures shall be used;
22.2.3 Technical and organisational measures shall be implemented to minimise the risk of errors. If errors occur, such measures must enable them to be easily corrected; and
22.2.4 All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling (see Parts 24 to 28 of this Policy for more details on data security).
22.3 If at any time an individual wishes to cease being included in profiling activity, they can alter their cookie preferences on our website. They can also choose to review the advanced settings in their search engine. Unfortunately, it is not possible for the Company to provide detailed instructions on generally turning permissions off as there are multiple search engines/ operating systems. The general option to block cookies is usually located in the advanced settings.

23. Personal Data Collected, Held, and Processed
The following personal data is collected, held, and processed by the Company (for details of data retention, please refer to the Company’s Data Retention Policy):

• name – to dispatch products to (contractual);
• over 18 age confirmation – for age rated products (if applicable) (contractual);
• business/company name – to dispatch products to (contractual);
• contact information such as email addresses, postal addresses and telephone numbers – for order queries (contractual);
• demographic information such as post code – profiling (legitimate interests/ consent options);
• IP address (automatically collected) (legitimate interests);
• Web browser type and version (automatically collected) (legitimate interests);
• operating system (automatically collected) (legitimate interests); and
• a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected and profiling) (legitimate interests/ consent options);

The lawful basis for processing is listed above by each activity. Any and all personal data collected by the Company is collected in order to ensure that the Company can provide the best possible service to its customers, and can work effectively with its business contacts, etc. The Company may also use personal data in meeting certain obligations imposed by law. This includes retaining information for as long as required for financial accounting purposes. For further information on the Company’s lawful basis for processing personal data please see the CKB Ltd ® Website Privacy & Cookies Policy/ Wholesale Gifts Tomorrow Website Privacy & Cookies Policy
Personal data may be disclosed within the Company and to trusted third parties; such disclosure is expected to comply with the UK-GDPR and this Policy. Personal data may be passed from one department/ party 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 or outwith 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. Such sharing of data may be necessary for the purpose of order fulfilment – for example, to fulfil a personalised order such as for lanyards. This may include a customer dealing directly with a third-party supplier for a product proof and delivery of their order.

24. Data Security – Transferring Personal Data and Communications
The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:
24.1 All emails containing personal data must be encrypted;
24.2 Personal data may be transmitted over secure networks only;
24.3 Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
24.4 Personal data contained in the body of an email, whether sent or received, is stored securely;
24.5 Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
24.6 Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using a secure method of delivery; and
24.7 All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.
Please refer to the Company Information Security Policy.

25. Data Security – Storage
The Company shall ensure that the following measures are taken with respect to the storage of personal data:
25.1 All electronic copies of personal data should be stored securely using passwords and data encryption;
25.2 All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;
25.3 All personal data stored electronically should be backed up regularly with backups stored offsite. All backups should be encrypted;
25.4 No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of the Company Director and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given (e.g. passcodes to unlock devices), and for no longer than is absolutely necessary; and
25.5 No personal data should be transferred to any device personally belonging to an employee unless appropriate approval from the Company Director has been given in line with the Company’s Bring Your Own Device to Work Policy. Personal data transferred to devices belonging to other parties working on behalf of the Company is expected to comply fully with the UK-GDPR/ this Policy (n.b. this may include demonstrating to the Company that all suitable technical and organisational measures have been taken).
Please refer to the Company Information Security Policy.

26. Data Security – Disposal
26.1 When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hard copies of data are to be securely shredded and electronic copies of data are to be securely deleted. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.
Please refer to the Company Information Security Policy.

27. Data Security – Use of Personal Data
The Company shall ensure that the following measures are taken with respect to the use of personal data:
27.1 No personal data may be shared informally and if an employee or party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from the Company Director;
27.2 No personal data may be transferred to any employees, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of the Company Director;
27.3 Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees or other parties at any time; and
27.4 If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it.
Please refer to the Company Information Security Policy.

28. Data Security – IT Security
The Company requires that the following measures are taken with respect to IT and information security:
28.1 All passwords used to protect personal data should be changed in accordance with the Company Information Security Policy and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols;
28.2 Under no circumstances should any passwords be written down or shared between any employees or other parties working on behalf of the Company, irrespective of seniority or department.
28.3 All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. Updates should be installed in line with the Company Information Security Policy; and
28.4 No new software may be installed on any Company-owned computer or device without the prior approval of the Company Director.

29. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
29.1 All employees or relevant other parties working on behalf of the Company can view both their individual responsibilities and the Company’s responsibilities under the UK-GDPR in this Policy;
29.2 Only employees or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
29.3 All employees handling personal data will be appropriately trained to do so;
29.4 All employees handling personal data will be appropriately supervised;
29.5 All employees or other parties working on behalf of the Company handling personal data shall be expected and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
29.6 Methods of collecting, holding, and processing personal data shall be regularly reviewed;
29.7 All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;
29.8 The performance of those working on behalf of the Company handling personal data shall be subject to review;
29.9 All employees or relevant other parties working on behalf of the Company handling personal data will be expected to do so in accordance with the principles of the UK-GDPR and this Policy;
29.10 All parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as outlined in this Part 29; and
29.11 Where any party working on behalf of the Company handling personal data fails in their obligations under the UK-GDPR and/ or this Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

30. Transferring Personal Data to a Country Outside the UK
30.1 The Company may from time-to-time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the UK. The UK-GDPR restricts such transfers to ensure that the level of protection given to data subjects is not compromised.
30.2 The transfer of personal data to a country outside of the UK shall take place only if one of the following applies:
30.2.1 The UK has issued regulations confirming that the country in question ensures an adequate level of protection (referred to as ‘adequacy decisions’ or ‘adequacy regulations’). Since 1st January 2021, transfers of personal data from the UK to EEA countries continue to be permitted. Pre-existing EU Commission adequacy decisions in effect pre-Brexit as at 31/12/2020 are also recognised, subject to ongoing review by the UK Government.
30.2.2 Appropriate safeguards in place include binding corporate rules, standard contractual clauses approved for use in the UK, an approved code of conduct, or an approved certification mechanism.
30.2.3 The transfer is made with the informed consent of the relevant data subject(s);
30.2.4 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 (or for pre-contractual steps taken at the request of the data subject); 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 for the Company’s legitimate interests.

31. Data Breach Notification
31.1 All personal data breaches must be reported immediately to the Company’s Data Protection Officer.
31.2 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.
31.3 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 31.2) to the rights and freedoms of data subjects, the Data Protection Officer must arrange for all affected data subjects to be informed of the breach directly and without undue delay.
31.4 Data breach notifications shall include the following information:
31.4.1 The categories and approximate number of data subjects concerned;
31.4.2 The categories and approximate number of personal data records concerned;
31.4.3 The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
31.4.4 The likely consequences of the breach;
31.4.5 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.

32. Notification to the Information Commissioner’s Office (ICO)
32.1 As a data controller, the Company is required to notify the ICO that it is processing personal data. The Company is registered in the register of data controllers under registration number ZA185276.

33. Implementation of Policy
33.1 This Policy shall be deemed effective as of 1st December 2024. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

V15 CKB Ltd Data Protection policy – effective date 1st December 2024