Data Protection Policy

Introduction

Waves Group Limited (The Company) recognises and accepts its responsibility as required by the EU General Data Protection Regulation, (GDPR), in force from 25^th May 2018. The Company, as a data controller, will take all reasonable steps to meet this responsibility and to promote good practice in the handling and use of personal information. In particular, the Company will comply with the data protection principles set out in the GDPR.

This policy statement applies to all employees, contracted associates, and individuals about whom the Company holds personal information, as well as other partners and companies with which the Company undertakes it business.

Scope

The Company needs to collect, hold and use certain types of personal information about people with whom it deals in order to operate. These include current, past and prospective employees, associates, suppliers, clients, and others with whom it communicates. In addition, it may be required by law to collect and use certain types of information to comply with the requirements of government departments. This personal information must be dealt with properly, however it is collected, recorded and used – whether on paper, in a computer, or recorded on other material – and there are safeguards to ensure this in the GDPR 2018.

We regard the lawful and correct treatment of personal information by the Company as essential in order to secure the successful execution of our operations, the delivery of our services, and to maintain the confidence of those with whom we deal. The Company wishes to ensure that it treats personal information lawfully, correctly and in compliance with the GDPR. To this end we fully endorse the obligations of the Act and adhere to the principles of data protection, as enumerated in the GDPR.

The following paragraphs provide a brief aid to the GDPR.

1. Main provisions of the GDPR legislation

(a)       Ensuring data controllers notify their processing of personal data with the Information Commissioners Office. The Company must supply certain information to the Commissioner who maintains a public register of the types of information organisations process, where it gets it from and what it does with it.

(b)       Observing the Data Protection Principles (more detail below).

(c)        Allowing the data subject to exercise his/her rights and have right of access to their personal information; what is held, how it is processed, to whom it is disclosed and to be told of the logic behind automated decisions.

2.Definitions

Data Controller

Any individual or organisation who controls personal data, in this instance, the Company.

Personal Data:

Information held on a relevant filing system, accessible record or computerised record (as well as digital audio or video equipment), which identifies living individuals.

Sensitive Personal Data:

Personal data relating to an individual’s race or ethnic origin, political opinions, religious beliefs, physical/mental health, trade union membership, sexual life and criminal activities.

Relevant Filing System:

Also known as manual records i.e. a set of records which are organised by reference to the individual/their criteria and are structured in such a way as to make specific information readily accessible e.g. personnel records, microfiches.

Data Subject:

An individual who is the subject of the personal data, for example, employees, members, claimants etc.

Processing:

Obtaining, recording or holding data or carrying out any operation on the data including organising, adapting, altering, retrieving, consulting, using, disclosing, disseminating, aligning, blocking, erasing or destroying the data.

Accessible Records:

Any records which are kept by the organisation as part of a statutory duty, e.g. pupil records, housing tenancy records, social services records.

3. Data Protection Principles (Article 5 GDPR)

1. Personal data shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met;
2. Personal data shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes;
3. Personal data shall be adequate, relevant and limited to what is necessary in relation to the purpose or purposes for which the data is held;
4. Personal data shall be accurate and, where necessary, kept up to date;
5. Personal data shall be 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 held.
6. Personal data shall be 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. 7. The controller shall be responsible for, and able to demonstrate compliance with, the GDPR

4. Commitment

Waves Group Limited (Cwaves and Mwaves) will, through appropriate management and application of criteria and controls:

• observe fully conditions regarding the fair collection and use of information;
• meet its legal obligations to specify the purposes for which information is used;
• collect and process appropriate information, and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements;
• ensure the quality of information used, including its accuracy and relevancy for the purpose(s) specified;
• apply strict checks to determine the length of time information is held;
• ensure that the rights of people about whom information is held can be fully exercised under GDPR. (These include: the right to be informed that processing is being undertaken: the right of access to one’s personal information; the right to prevent processing in certain circumstances; the right to correct, block or erase information which is regarded as erroneous);
• take appropriate technical and organisational security measures to safeguard personal information; and ensure that personal information is not transferred abroad without suitable safeguards.

5. Compliance

In addition, the Company takes steps to ensure that:

• There is someone with specific responsibility for data protection in the organisation (The Data Controller);
• Everyone managing and handling personal information understands that they are contractually responsible for following good data protection practice;
• Everyone managing and handling personal information is appropriately trained to do so;
• Everyone managing and handling personal information is appropriately supervised;
• Anybody wanting to make enquiries about handling personal information knows what to do;
• Queries about handling personal information are promptly and courteously dealt with;
• Methods of handling personal information are clearly described;
• A regular review and audit is made of the way personal information is managed;
• Methods of handling personal information are regularly assessed and evaluated;
• Performance of handling personal information is regularly assessed and evaluated;
• It disseminates to employees, information on good practice in respect of handling, using and storing personal information.