Brabourne Ltd – Data Retention Policy & Privacy Notice

1. Introduction
This policy sets out the obligations of Brabourne Ltd regarding retention of personal data collected, held, and processed by Brabourne Ltd in accordance with EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The 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.

The GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, 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.

Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to

the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).

In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:

a) Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);
b) When the data subject withdraws their consent;
c) When the data subject objects to the processing of their personal data and Brabourne Ltd has no overriding legitimate interest;

d) When the personal data is processed unlawfully (i.e. in breach of the GDPR);
e) When the personal data has to be erased to comply with a legal obligation; or

f) Where the personal data is processed for the provision of information society services to a child.
This policy sets out the type(s) of personal data held by Brabourne Ltd for professional purposes, the period(s) for which that personal data is to be retained, the criteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of.
For further information on other aspects of data protection and compliance with the GDPR, please refer to the Brabourne Ltd Data Protection Policy.

2. Aims and Objectives
2.1 The primary aim of this policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this policy

aims to ensure that Brabourne Ltd complies fully with its obligations and the rights of data subjects under the GDPR.
2.2 In addition to safeguarding the rights of data subjects under the GDPR, by ensuring that excessive amounts of data are not retained by Brabourne Ltd, this policy also aims to improve the speed and efficiency of managing data.

3. Scope
3.1 This policy applies to all personal data held by Brabourne Ltd and/or for professional purposes and by third-party data processors processing personal data on behalf of Brabourne Ltd.
3.2 Personal data, as held by the above is stored in the following ways and in the following locations:
a) Third-party servers, operated by Xero and located in a cloud based system;
b) Computers permanently located at Brabourne Ltd premises;
c) Laptop computers and other mobile devices provided by Brabourne Ltd to its employees;
e) Physical records stored at Brabourne Ltd premises

4. Data Subject Rights and Data Integrity
All personal data held by Brabourne Ltd is held in accordance with the requirements of the GDPR and data subjects’ rights thereunder, as set out in the Brabourne Ltd Data Protection Policy.
4.1 Data subjects are kept fully informed of their rights, of what personal data Brabourne Ltd holds about them, how that personal data is used as set out in the Brabourne Ltd Data Protection Policy, and how long Brabourne Ltd will hold that personal data. Data subjects are given control over their personal data held by Brabourne Ltd including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the

right to restrict Brabourne Ltd use of their personal data.
5. Technical and Organisational Data Security Measures
5.1 The following technical measures are in place within Brabourne Ltd to protect the security of personal data. Please refer to Brabourne Ltd Data Protection Policy for further details:
a) All emails containing personal data must be marked “confidential”; b) Personal data may only be transmitted over secure networks;
c) Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;
d) Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;
e) Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;
f) Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient or sent using Royal Mail services;
g) All personal data transferred physically should be transferred in a suitable container marked “confidential”;
h) No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from a company director.
i) All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;
j) No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of Brabourne Ltd or not, without authorisation;
k) Personal data must be handled with care at all times and should not be left unattended or on view;
l) Computers used to view personal data must always be locked before being left unattended;

m) No personal data should be stored on any mobile device, whether such device belongs to Brabourne Ltd or otherwise without the formal written approval of a director and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary;

n) No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of Brabourne Ltd where the party in question has agreed to comply fully with Brabourne Ltd Data Protection Policy and the GDPR; o) All personal data stored electronically should be backed up every day with backups stored offsite. All backups should be encrypted;

p) All electronic copies of personal data should be stored securely. All passwords used to protect personal data should be changed regularly. Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

q) All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;
r) No software may be installed on any Brabourne Ltd-owned computer or device without approval; and

s) Where personal data held by Brabourne Ltd is used for marketing purposes, it shall be the responsibility of a company director to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.

5.2 The following organisational measures are in place within Brabourne Ltd to protect the security of personal data. Please refer to Brabourne Ltd Data Protection Policy for further details:
a) All employees and other parties working on behalf of Brabourne Ltd shall be made fully aware of both their individual responsibilities and

Brabourne Ltd responsibilities under the GDPR and under the Brabourne Ltd Data Protection Policy;
b) Only employees and other parties working on behalf of Brabourne Ltd that need access to, and use of, personal data in order to perform their work shall have access to personal data held by Brabourne Ltd; c) All employees and other parties working on behalf of Brabourne Ltd handling personal data will be appropriately trained to do so;
d) All employees and other parties working on behalf of Brabourne Ltd handling personal data will be appropriately supervised;
e) All employees and other parties working on behalf of Brabourne Ltd handling personal data should exercise care and caution when discussing any work relating to personal data at all times;
f) Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
g) The performance of those employees and other parties working on behalf of Brabourne Ltd handling personal data shall be regularly evaluated and reviewed;
h) All employees and other parties working on behalf of Brabourne Ltd handling personal data will be bound by contract to comply with the GDPR and Brabourne Ltd Data Protection Policy;
i) All agents, contractors, or other parties working on behalf of Brabourne Ltd handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of Brabourne Ltd arising out of the GDPR and Brabourne Ltd Data Protection Policy;
j) Where any agent, contractor or other party working on behalf of Brabourne Ltd handling personal data fails in their obligations under the GDPR and/or Brabourne Ltd Data Protection Policy, that party shall indemnify and hold harmless Brabourne Ltd against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

6. Data Disposal
Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:
6.1 Personal data stored electronically including any and all backups thereof shall be deleted securely;
6.2 Special category personal data stored electronically including any and all backups thereof shall be deleted;
Personal data stored in hardcopy form shall be shredded and recycled. Special category personal data stored in hardcopy form shall be shredded and recycled

7. Data Retention
7.1 As stated above, and as required by law, Brabourne Ltd shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.
7.2 Different types of personal data, used for different purposes, will necessarily be retained for different periods and its retention periodically reviewed, as set out below.
7.3 When establishing and/or reviewing retention periods, the following shall be taken into account:
a) The objectives and requirements of Brabourne Ltd;
b) The type of personal data in question;
c) The purpose(s) for which the data in question is collected, held, and processed;
d) Brabourne Ltd legal basis for collecting, holding, and processing that data;
e) The category or categories of data subject to whom the data relates; 7.4 If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the

retention of that data, can be regularly reviewed against those criteria. 7.5 Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within Brabourne Ltd to do so (whether in response to a request by a data subject or otherwise).

7.6 In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the GDPR.

8. Roles and Responsibilities
8.1 Brabourne Ltd Appointed Person is Mr S Hugessen,.
8.2 The Appointed Person shall be responsible for overseeing the implementation of this policy and for monitoring compliance with this policy, Brabourne Ltd other Data Protection-related policies (including, but not limited to, its Data Protection Policy), and with the GDPR and other applicable data protection legislation.
8.3 The Appointed Person shall be directly responsible for ensuring compliance with the above data retention periods throughout Brabourne Ltd
8.4 Any questions regarding this policy, the retention of personal data, or any other aspect of GDPR compliance should be referred to the Appointed Person.

9. Implementation of Policy
This policy shall be deemed effective as of 08/05/2018. No part of this policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

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