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 Welcome to the Cross Keys Hotel Chatteris

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Terms & Conditions (T&C's)

Please refer to our Terms & Conditions which is also downloadable in PDF format.

 

Cross Keys Hotel

12-16 Market Hill

Chatteris

Cambridgeshire PE16 6BA

01354 692644 & 01354 693066

Email: info@crosskeyschatteris.com

Web: www.crosskeyschatteris.com

Cross Keys Hotel Terms and Conditions (‘T&C’s)

Thank you for choosing to book with the Cross Keys Hotel. We look forward to welcoming you to our family hotel. By making this booking you are entering a legally binding contract with us. Please read our terms and conditions of booking below.

Prices

The price includes accommodation and full English breakfast. Please advise upon booking any dietary requirements e.g. Food allergies, Vegetarian, Celiac, etc.

Booking Confirmation & Deposit:

Currently we ask for at least a 50% deposit and payment in full is required on arrival.

Bookings by email are confirmed by return email and still require 50% deposit.

Cancellation of booking

Notice of cancellation of booking: providing we have at least 48 hours’ notice of cancellation no payments will be due and any money paid as a deposit will be refunded in full.

Payment

Payment of any outstanding balance should be made on arrival by either cash, credit or debit card. We do not charge any fees for use of a credit card. All credit card transactions are secure and no data collected is offered to third parties for any reason. All transactions comply with the relevant legal requirements at the time of the transaction.

Non-availability of Accommodation

We would only cancel your stay if your accommodation was unavailable for reasons beyond our control. We would however attempt to find you alternative accommodation, if we were unable to find suitable accommodation our liability would not extend beyond this point.

Parking

Parking spaces are free and available on a first come first served basis. If no spaces are available upon your arrival, please ask for details of other free parking within easy walking distance.

Pets

We do allow pets inside the bar area otherwise pets are not allowed in the rooms or restaurant area under any circumstances.  Should any pet be taken into a room, there will be a £100 cleaning charge.

Acceptance of Children

We welcome children and by prior arrangement and free of charge, can provide a highchair. We would ask you to bring your own travel cot and preferably your own bedding for the cot.

Arrival

Your accommodation will be available to you from 3:00 pm on the day of arrival, unless otherwise arranged. We may not be able to accommodate you if you arrive earlier than the agreed time as we will be busy preparing your rooms. However, you may drop off your bags, pay for your stay and collect your room keys at an earlier time by prior arrangement.

It is much appreciated if you will notify us of your estimated time of arrival (a telephone call on the day before or morning of arrival is fine).

Late arrival procedure

Please ensure you contact us to let us know if you will be arriving later than 10:30 pm, and inform us of your new estimated time of arrival. We do not normally accept guests after 11:00 pm.

Room Vacation

Please vacate your room by 11:00 am, unless otherwise arranged. The room will be ready for re-occupation from 3:00 pm, unless otherwise arranged.

Rooms

Eating take away meals in rooms is not allowed as they can leave after smells and can cause staining if the food comes into contact with bedding or carpets etc. We accept that sandwiches and drinks can be consumed in the rooms but care should be taken to avoid spillage etc.

Smoking

In accordance with UK Law there is a no smoking policy in force at the Cross Keys Hotel.

Smoking in the designated outside area is acceptable.

There is a fire alarm system in operation and if this is set off by guests smoking anywhere in the house you will be asked to vacate the premises and forfeit any monies paid, this is non-negotiable.

This applies to anybody who deliberately covers a smoke detector anywhere on the premises.

Damages and Breakages

Please take care when staying in our hotel. You are responsible and liable for any breakages or damages which you cause to the accommodation or its contents. We ask that you report any incidents when they occur. We do not normally charge for minor breakages, but we may charge you for repair or making good if the damage or breakage is significant.  Significant care must be taken when using Macerators (there are three in the ‘old’ part of the hotel covering Rooms 5, 6/7 (shared bathroom) and Room 8).  Macerators are used to overcome strict building regulations and under no circumstances are any plastic, tampons or hard substances to be flushed down the toilet. The repair charge for a macerator is currently £650.

Liability

We do not accept any liability for any damage, loss or injury to any member of your party or any vehicles or possessions, unless proven to be caused by a negligent act by ourselves or our employees or contractors whilst acting in the course of employment.

Privacy Policy

Any data collected during the course of this booking will be stored on our computer(s).  Please see our GDPR Policy which is readily available on our website.

Emergency Contact

In the unlikely event you encounter an out of hours emergency then please contact the proprietors on their mobile phone:

David Leaning (First Point of Contact): 07818 418755

Rebecca Leaning (Second Point of Contact): 07850 518808

Out of Hours landline number (Detached house in the grounds) 01354 694555

Wi-Fi Access

The SSID for Patrons and Residents at the Cross Keys:

Wi-Fi: Cross-keys-chatteris

Passphrase: 12-16MarketHill

This is monitored and any abuse will result in your MAC address being blocked.

Meal Timings

Breakfast: Monday – Friday 7:30 am – 9:30 am

Breakfast: Saturday – Sunday 8:30 am – 9:30 am

Lunch: Monday – Sunday Noon – 2:00 pm

Evening Meals: Monday – Saturday 7:00 pm – 9:00 pm

 

We hope you enjoy your stay!

 

GDPR (General Data Protection Regulations)

The Cross Keys Management takes their legal, moral and ethical responsibilities very seriously. As a result, we have published our GDPR Policy (29 pages). GDPR becomes EU law on 25th May 2018.

                                                                       

Cross Keys Hotel GDPR

(General Data Protection Regulations) Policy

 

Author: David Leaning

Dated: 08 APR 18

 

 

Revision Table

Authorship of GDPR Policy (this document)

06 APR 18

Ver 0.1

Proof read and minor corrections

07 APR 18

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Final version approved

08 APR 18

Ver 1.0

 

This Policy Document remains the Intellectual Property of the Cross Keys Hotel.  This Policy document has been prepared for the exclusive use and benefit of the addressee(s) and solely for the purpose for which it is provided. Unless the Cross Keys Management provide express prior written consent, no part of this report should be reproduced, distributed or communicated to any third party. We do not accept any liability if this report is used for an alternative purpose from which it is intended, nor to any third party in respect of this report.

 

 

Contents

1. Introduction

2. Scope

3. Cross Keys Hotel General Data Policy Statement

3.1 Personal Data

3.2 Processing of Personal Data

3.3 Sensitive Personal Data

3.4 Rights of Access to Information

3.5 Exemptions

3.6 Accuracy

3.7 Enforcement

3.8 Data Security

3.9 External Processors

3.10 Secure Destruction

3.11 Retention of Data

3.12 CCTV

3.13 GDPR Principles

3.14 The Cross Keys Hotel GDPR Internal Network

3.15 Secure working environment

3.16 Training module (GDPR Principle 7)

3.17 Policy acknowledgement (GDPR Article 30)

3.18 Secure document library (GDPR Article 35)

3.19 Subject Access Requests (SARs) (GDPR Article 15)

3.20 Breach reporting (GDPR Articles 33 and 34)

3.21 Auditing and record keeping (GDPR Article 30)

3.22 Data Subject Access (GDPR Articles 15, 16, 17, 18, 19 and 20)

4. Definitions

5. Policy

5.1 Governance

5.1.1 Cross Keys Hotel Management

5.1.2 Policy Dissemination & Enforcement

5.1.3 Data Protection by Design

5.1.4 Compliance Monitoring

5.2 Data Protection Principles

5.3 Data Collection

5.3.1 Data Sources

5.3.2 Data Subject Consent

5.3.3 Data Subject Notification

5.3.4 External Privacy Notices

5.4 Data Use

5.4.1 Data Processing

5.4.1 Data Processing

5.4.2 Special Categories of Data

5.4.3 Children’s Data

5.4.4 Data Quality

5.4.5 Profiling & Automated Decision-Making

5.4.6 Digital Marketing

5.5 Data Retention

5.6 Data Protection

5.7 Data Subject Requests

5.8 Law Enforcement Requests & Disclosures

5.9 Data Protection Training

5.10 Data Transfers

5.10.1 Transfers between Cross Keys Hotel Entities

5.10.2 Transfers to Third Parties

5.10.3 Data Breaches

5.11 Complaints Handling

5.12 Breach Reporting

6. Policy Maintenance

6.1 Publication

6.2 Effective Date

6.3 Revisions

7. Related Documents

Appendix A - Information Notification to Data Subjects

Appendix B - Adequacy for Personal Data Transfers

 

 

 

The Cross Keys Hotel, 12-16 Market Hill, Chatteris, Cambridgeshire PE16 6BA (“Cross Keys Hotel”) is committed to conducting its business in accordance with all applicable Data Protection laws and regulations and in line with the highest standards of ethical conduct.

This policy sets forth the expected behaviours of Cross Keys Hotel Employees and Third Parties in relation to; the collection, use, retention, transfer, disclosure and destruction of any Personal Data belonging to a Cross Keys Hotel Contact (i.e. the Data Subject).

Personal Data is any information (including opinions and intentions) which relates to an identified or Identifiable Natural Person. Personal Data is subject to certain legal safeguards and other regulations, which impose restrictions on how organisations may process Personal Data.

An organisation that handles Personal Data and makes decisions about its use is known as a Data Controller. Cross Keys Hotel, as a Data Controller, is responsible for ensuring compliance with the Data Protection requirements outlined in this policy. Non-compliance may expose Cross Keys Hotel to complaints, regulatory action, fines and/or reputational damage.

Cross Keys Hotel’s leadership is fully committed to ensuring continued and effective implementation of this policy, and expects all Cross Keys Hotel Employees and Third Parties to share in this commitment. Any breach of this policy will be taken seriously and may result in disciplinary action or business sanction.

This policy has been approved by Cross Keys Hotel’s Proprietor, David Leaning.

This policy applies to all Cross Keys Hotel Entities where a Data Subject’s Personal Data is processed:

• In the context of the business activities of the Cross Keys Hotel Entity.

• For the provision or offer of goods or services to individuals (including those provided or offered free-of-charge) by a Cross Keys Hotel Entity.

• To actively monitor the behaviour of individuals.

• Monitoring the behaviour of individuals includes using data processing techniques such as persistent web browser cookies or dynamic IP address tracking to profile an individual with a view to:

• Taking a decision about them.

• Analysing or predicting their personal preferences, behaviours and attitudes.

This policy applies to all Processing of Personal Data in electronic form (including electronic mail and documents created with word processing software) or where it is held in manual files that are structured in a way that allows ready access to information about individuals.

This policy has been designed to establish a worldwide baseline standard for the Processing and protection of Personal Data by all Cross Keys Hotel Entities. Where national law imposes a requirement which is stricter than imposed by this policy, the requirements in national law must be followed. Furthermore, where national law imposes a requirement that is not addressed in this policy, the relevant national law must be adhered to.  The Cross Keys Hotel also addresses GDPR (General Data Protection Regulations) which harmonises the present 27 disparate Data Processing Laws spanning the present EU.

If there are conflicting requirements in this policy and UK law or GDPR, please consult with Cross Keys Hotel Management for guidance.

The protection of Personal Data belonging to Cross Keys Hotel Employees is not within the scope of this policy. It is covered in the Cross Keys Hotel ‘Data Protection for Employee Data’ policy.

 

The Cross Keys is required to process relevant personal data regarding members of staff, residents and customers as part of its operation and shall take all reasonable steps to do so in accordance with this Policy.

 

The Cross Keys Hotel recognises The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) adopted 27 April 2016, the two-year transition period and the application date of 25 May 2018 and is actively working towards compliance with that directive. All Staff shall so far as is reasonably practicable comply with the Data Protection Principles (the Principles) contained in the Data Protection Act to ensure all data is:

Fairly and lawfully processed

Processed for a lawful purpose

Adequate, relevant and not excessive

Accurate and up to date

Not kept for longer than necessary

Processed in accordance with the data subject's rights • Secure

Not transferred to other countries without adequate protection

 

Personal data covers both facts and opinions about an individual where that data identifies an individual. For example, it includes information necessary for employment such as the member of staff’s name and address and details for payment of salary or a pupil’s attendance record and exam results. Personal data may also include sensitive personal data as defined in the Act.

 

Consent may be required for the processing of personal data unless processing is necessary for the performance of the contract of employment. Any information which falls under the definition of personal data and is not otherwise exempt, will remain confidential and will only be disclosed to third parties with appropriate consent.

 

The Hotel may, from time to time, be required to process sensitive personal data. Sensitive personal data includes data relating to financial card details, names, vehicle registration details and any special dietary requirements et al.

 

Data subjects have the right of access to information held by the Hotel, subject to the provisions of the Data Protection Act 1998 and the General Data Protection Regulations (GDPR).

 

Certain data is exempted from the provisions of the Data Protection Act which includes the following:

 

National security and the prevention or detection of crime

The assessment of any tax or duty

Where the processing is necessary to exercise a right or obligation conferred or imposed by law upon the Hotel, including Safeguarding and prevention of terrorism and radicalisation.

 

The above are examples only of some of the exemptions under the Act. Any further information on exemptions should be sought direct from the hotel owners.

 

The Cross Keys Hotel will endeavour to ensure that all personal data held in relation to all data subjects is accurate. Data subjects must notify the data processor of any changes to information held about them. Data subjects have the right in some circumstances to request that inaccurate information about them is erased. This does not apply in all cases, for example, where records of mistakes or corrections are kept, or records which must be kept in the interests of all parties to which they apply.

 

If an individual believes that the Cross Keys Hotel has not complied with this Policy or acted otherwise than in accordance with the Data Protection Act, the individual(s) should utilise the Hotel Grievance Procedure and should also notify the DPC.

 

The Hotel will take appropriate technical and organisational steps to ensure the security of personal data. All staff will be made aware of this policy and their duties under the Act.

The Cross Keys Hotel and therefore all staff and owners are required to respect the personal data and privacy of others and must ensure that appropriate protection and security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to all personal data.

An appropriate level of data security must be deployed for the type of data and the data processing being performed. In most cases, personal data must be stored in appropriate systems and be encrypted when transported offsite. Other personal data may be for publication or limited publication within the Hotel, therefore having a lower requirement for data security.

Attention is also drawn to the existence of the Information and Computing Technology (ICT) Policy, which provides more specific information on digital data protection within the ICT policy.

 

The Hotel must ensure that data processed by external processors, for example, service providers, Cloud services including storage, web sites etc. are compliant with this policy and the relevant legislation.

 

When data held in accordance with this policy is destroyed, it must be destroyed securely in accordance with best practice at the time of destruction.

 

The Hotel may retain data for differing periods of time for different purposes as required by statute or best practices, individual departments incorporate these retention times into the processes and manuals. Other statutory obligations, legal processes and enquiries may also necessitate the retention of certain data. The Hotel may store some data such as registers, photographs, exam results, achievements, books and works etc. indefinitely in its archive.

 

The Hotel owns and operates a CCTV network for the purposes of crime prevention and detection, and Safeguarding.

Where a data subject can be identified, images must be processed as personal data.

 

The Cross Keys Hotel recognises the following GDPR Principles within its Data Protection Policy:

 

Staff training (GDPR Principle 7)

Breach reporting (GDPR Articles 33 and 34)

Record keeping (GDPR Article 30)

Subject access requests (GDPR Article 15)

Security and auditing (GDPR Article 30)

Data subject access (GDPR Articles 15, 16, 17, 18, 19 and 20)

Secure document storage (GDPR Article 35)

Policy distribution (GDPR Article 30)

 

The GDPR requires that businesses not only comply with a wide range of conditions but also that once compliant, a business is able to provide evidence and demonstrate a continuing compliance. The Network has been designed by David Leaning, the Proprietor of the Cross Keys Hotel.

 

Compliance normally involves a number of people working together, often remotely and with contributions from persons, external to an organisation. The Network provides an extremely secure, internet based environment. It contains a secure room booking system, document and calendar sharing together with a wide range of other features. Workflows can provide alerts when documents are changed or uploaded and create document information flows. Security can be set to include dual validation for users, which requires the use of both a secure password and a text sent to a previously specified mobile phone, to gain access.

 

A comprehensive training facility that provides online learning, multiple choice testing and a certification option, together with the ability to record and report on usage. Staff training in data protection, both initial and ongoing, is a key component in demonstrating compliance with the GDPR.

 

Another key aspect of compliance, being able to record and document both the distribution and acknowledgement of policies. When a staff member logs in to the Network, the policy acknowledgement facility blocks any Network use, until they have accessed the specified policy. Reporting can detail the dates and times of access etc. together with users that have or haven’t accessed the required policies. This reporting provides excellent and required evidence for compliance. It is also possible to use this facility for awareness campaigns.

 

Data Protection Impact Assessments (DPIAs), Privacy Notices, policies, training and other manuals can be stored on the Network, in a permissions based system.

 

A digital form can be published on the Network to permit the organized collection of SARs from clients/customers. Further, any SARs that are received in any other way, can be logged into this section. The response time to a SAR is subject to specific time limits and warnings etc. can be configured in this section.

 

A breach reporting system is absolutely essential for compliance. Date and time stamping is built into the system, providing excellent evidence of compliance, from the reporting of a breach, together with actions undertaken in relation to that breach.

 

Workflows or digital forms can be used to provide evidence of audits and data processing activities.

 

One of the biggest problem areas for organisations is to fulfil the ‘right’ of a data subject (client/customer) to have access to their Personal Identifiable Information (PII), the key and fundamental component of the GDPR. Access must be provided, together with a facility to erase, amend, transfer or stop the processing of a data subject’s PII, when it is the subject of a SAR.

 

Depending upon an organisation, the amount of PII data that they hold and the nature of their processing of that data, this facility can be either extremely simple or very complex. Many organisations have multiple databases, where PII information may be duplicated. In a simple scenario, where there is little processing of PIIs, few SARs being received and only one database containing the information, then it is possible to import/export the specific data into the Network, when a SAR is received.

The data subject would then be provided with a username/secure password to access their data, on the Network, where they will have the facility to amend, delete, stop processing or download a csv file copy of the data, as they require. The system would advise of any changes that they have made, which would then be replicated on to the database. A workflow system would control this, to manage, document and evidence the process.

 

For future-proofing within the expansion plans of the Cross Keys Hotel, a more complex environment, database(s) would be fed, live into the Network, or uploaded at fixed intervals, to provide an automated access solution to satisfy SAR requests. The feed would work both ways so that once a data subject amended their details, any such change could be replicated back to the main database(s). Obviously, this is a complex solution, which would be determined by the Cross Keys Hotel individual requirements and their existing IT systems and platforms.

EmployeeAn individual who works part-time or full-time for Cross Keys Hotel under a contract of employment, whether oral or written, express or implied, and has recognised rights and duties. Includes temporary employees and independent contractors.

Third Party

An external organisation with which Cross Keys Hotel conducts business and is also authorised to, under the direct authority of Cross Keys Hotel, Process the Personal Data of Cross Keys Hotel Contacts.

Personal Data

Any information (including opinions and intentions) which relates to an identified or Identifiable Natural Person.

Contact

Any past, current or prospective Cross Keys Hotel customer.

Identifiable Natural Person

Anyone 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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data Controller

A natural or legal person, Public Authority, Agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

Cross Keys Hotel Entity

A Cross Keys Hotel establishment, including subsidiaries and joint ventures over which Cross Keys Hotel exercise management control.

Data Subject

The identified or Identifiable Natural Person to which the data refers.

Process, Processed, Processing

Any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means. Operations performed may include collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Data Protection

The process of safeguarding Personal Data from unauthorised or unlawful disclosure, access, alteration, Processing, transfer or destruction.

Data Protection Authority

An independent Public Authority responsible for monitoring the application of the relevant Data Protection regulation set forth in national law.

Data Processors

A natural or legal person, Public Authority, Agency or other body which Processes Personal Data on behalf of a Data Controller.

Consent

Any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.

Special Categories of Data Personal

Data pertaining to or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; data concerning health or sex life and sexual orientation; genetic data or biometric data.

Third Country

Any country not recognised as having an adequate level of legal protection for the rights and freedoms of Data Subjects in relation to the Processing of Personal Data.

Profiling

Any form of automated processing of Personal Data where Personal Data is used to evaluate specific or general characteristics relating to an Identifiable Natural

Person

In particular to analyse or predict certain aspects concerning that natural person’s performance at work, economic situations, health, personal preferences, interests, reliability, behaviour, location or movement.

Binding Corporate Rules

The Personal Data protection policies used for the transfer of Personal Data to one or more Third Countries within a group of undertakings, or group of enterprises engaged in a joint economic activity.

Personal Data Breach

A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

Encryption

The process of converting information or data into code, to prevent unauthorised access.

Pseudonymisation

Data amended in such a way that no individuals can be identified from the data (whether directly or indirectly) without a “key” that allows the data to be re-identified.

Anonymisation

Data amended in such a way that no individuals can be identified from the data (whether directly or indirectly) by any means or by any person.

To demonstrate our commitment to Data Protection, and to enhance the effectiveness of our compliance efforts, the Cross Keys Hotel has established a separate management role. The role operates with independence and is staffed by suitability skilled individuals granted all necessary authority. The role of Data Protection has the following duties, which includes:

• Informing and advising Cross Keys Hotel and its Employees who carry out processing pursuant to Data Protection regulations, national law or Union based Data Protection provisions;

• Ensuring the alignment of this policy with Data Protection regulations, national law or Union based Data Protection provisions;

• Providing guidance with regards to carrying out Data Protection Impact Assessments (DPIAs);

• Acting as a point of contact for and cooperating with Data Protection Authorities (DPAs);

• Determining the need for notifications to one or more DPAs as a result of Cross Keys Hotel’s current or intended Personal Data processing activities;

• Making and keeping current notifications to one or more DPAs as a result of Cross Keys Hotel’s current or intended Personal Data processing activities;

• The establishment and operation of a system providing prompt and appropriate responses to Data Subject requests;

• Informing Employees and Third Parties of Cross Keys Hotel of any potential corporate, civil and criminal penalties which may be levied against Cross Keys Hotel and/or its Employees for violation of applicable Data Protection laws.

• Ensuring establishment of procedures and standard contractual provisions for obtaining compliance with this Policy by any Third Party who:

• provides Personal Data to a Cross Keys Hotel Entity

• receives Personal Data from a Cross Keys Hotel Entity

• has access to Personal Data collected or processed by a Cross Keys Hotel Entity.

The management team of each Cross Keys Hotel Entity must ensure that all Cross Keys Hotel Employees responsible for the Processing of Personal Data are aware of and comply with the contents of this policy.

In addition, each Cross Keys Hotel Entity will make sure all Third Parties engaged to Process Personal Data on their behalf (i.e. their Data

Processors) are aware of and comply with the contents of this policy.

Assurance of such compliance must be obtained from all Third Parties, whether companies or individuals, prior to granting them access to Personal Data controlled by the Cross Keys Hotel.

To ensure that all Data Protection requirements are identified and addressed when designing new systems or processes and/or when reviewing or expanding existing systems or processes, each of them must go through an approval process before continuing.

Each Cross Keys Hotel Entity must ensure that a Data Protection Impact Assessment (DPIA) is conducted, in cooperation with the Cross Keys Hotel Management, for all new and/or revised systems or processes for which it has responsibility. The subsequent findings of the DPIA must then be submitted to the Chief Risk Officer for review and approval. Where applicable, the Information Technology (IT) function of the Cross Keys, as part of its IT system and application design review process, will cooperate with the Cross Keys Hotel Management to assess the impact of any new technology uses on the security of Personal Data.

To confirm that an adequate level of compliance that is being achieved by all Cross Keys Hotel Entities in relation to this policy, the Cross Keys Hotel Management will carry out an annual Data Protection compliance audit for all such Entities. Each audit will, as a minimum, assess:

• Compliance with Policy in relation to the protection of Personal Data, including:

• The assignment of responsibilities.

• Raising awareness.

• Training of Employees.

• The effectiveness of Data Protection related operational practices, including:

• Data Subject rights.

• Personal Data transfers.

• Personal Data incident management.

• Personal Data complaints handling.

• The level of understanding of Data Protection policies and Privacy Notices.

• The currency of Data Protection policies and Privacy Notices.

• The accuracy of Personal Data being stored.

• The conformity of Data Processor activities.

• The adequacy of procedures for redressing poor compliance and Personal Data Breaches.

The Cross Keys Hotel Management, in cooperation with key business stakeholders from each Cross Keys Hotel Entity, will devise a plan with a schedule for correcting any identified deficiencies within a defined and reasonable time frame. Any major deficiencies identified will be reported to and monitored by the Cross Keys Hotel Executive Management team.

Cross Keys Hotel has adopted the following principles to govern its collection, use, retention, transfer, disclosure and destruction of Personal Data:

• Principle 1: Lawfulness, Fairness and Transparency

Personal Data shall be processed lawfully, fairly and in a transparent manner in relation to the Data Subject. This means, Cross Keys Hotel must tell the Data Subject what Processing will occur (transparency), the Processing must match the description given to the Data Subject (fairness), and it must be for one of the purposes specified in the applicable Data Protection regulation (lawfulness).

• Principle 2: Purpose Limitation

Personal Data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. This means Cross Keys Hotel must specify exactly what the Personal Data collected will be used for and limit the Processing of that Personal Data to only what is necessary to meet the specified purpose.

• Principle 3: Data Minimisation

Personal Data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

This means Cross Keys Hotel must not store any Personal Data beyond what is strictly required.

• Principle 4: Accuracy

Personal Data shall be accurate and, kept up to date.

This means Cross Keys Hotel must have in place processes for identifying and addressing out-of-date, incorrect and redundant Personal Data.

• Principle 5: Storage Limitation

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 processed. This means Cross Keys Hotel must, wherever possible, store Personal Data in a way that limits or prevents identification of the Data Subject.

• Principle 6: Integrity & Confidentiality

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. Cross Keys Hotel must use appropriate technical and organisational measures to ensure the integrity and confidentiality of Personal Data is maintained at all times.

• Principle 7: Accountability

The Data Controller shall be responsible for, and be able to demonstrate compliance. This means Cross Keys Hotel must demonstrate that the six Data Protection Principles (outlined above) are met for all Personal Data for which it is responsible.

Personal Data should be collected only from the Data Subject unless one of the following apply:

• The nature of the business purpose necessitates collection of the Personal Data from other persons or bodies.

• The collection must be carried out under emergency circumstances in order to protect the vital interests of the Data Subject or to prevent serious loss or injury to another person.

If Personal Data is collected from someone other than the Data Subject, the Data Subject must be informed of the collection unless one of the following apply:

• The Data Subject has received the required information by other means.

• The information must remain confidential due to a professional secrecy obligation

• A national law expressly provides for the collection, Processing or transfer of the Personal Data.

Where it has been determined that notification to a Data Subject is required, notification should occur promptly, but in no case later than:

A list of the disclosures that need to be made available to the Data Subject is provided in Appendix A

Each Cross Keys Hotel Entity will obtain Personal Data only by lawful and fair means and, where appropriate with the knowledge and Consent of the individual concerned. Where a need exists to request and receive the

Consent of an individual prior to the collection, use or disclosure of their Personal Data, Cross Keys Hotel is committed to seeking such Consent.

The Cross Keys Hotel Management will establish a system for obtaining and documenting Data Subject Consent for the collection, Processing, and/or transfer of their Personal Data. The system must include provisions for:

• Determining what disclosures should be made in order to obtain valid Consent.

• Ensuring the request for consent is presented in a manner which is clearly distinguishable from any other matters, is made in an intelligible and easily accessible form, and uses clear and plain language.

• Ensuring the Consent is freely given (i.e. is not based on a contract that is conditional to the Processing of Personal Data that is unnecessary for the performance of that contract).

• Documenting the date, method and content of the disclosures made, as well as the validity, scope, and volition of the Consents given.

• Providing a simple method for a Data Subject to withdraw their Consent at any time.

• One calendar month from the first collection or recording of the Personal Data

• At the time of first communication if used for communication with the Data Subject

• At the time of disclosure if disclosed to another recipient.

Each Cross Keys Hotel Entity will, when required by applicable law, contract, or where it considers that it is reasonably appropriate to do so, provide Data Subjects with information as to the purpose of the Processing of their Personal Data.

When the Data Subject is asked to give Consent to the Processing of Personal Data and when any Personal Data is collected from the Data Subject, all appropriate disclosures will be made, in a manner that draws attention to them, unless one of the following apply:

• The Data Subject already has the information

• A legal exemption applies to the requirements for disclosure and/or Consent.

The disclosures may be given orally, electronically or in writing. If given orally, the person making the disclosures should use a suitable script or form approved in advance by the Cross Keys Hotel Management. The associated receipt or form should be retained, along with a record of the facts, date, content, and method of disclosure.

Each external website provided by a Cross Keys Hotel Entity will include an online ‘Privacy Notice’ and an online ‘Cookie Notice’ fulfilling the requirements of applicable law.

Refer to Cross Keys Hotel’s ‘Internet Privacy Notice’ and ‘Internet Cookie Notice’ standard templates for guidance. All Privacy and Cookie Notices must be approved by the

Cross Keys Hotel Management prior to publication on any Cross Keys Hotel external website.

Cross Keys Hotel uses the Personal Data of its Contacts for the following broad purposes:

• The general running and business administration of Cross Keys Hotel Entities.

• To provide services to Cross Keys Hotel customers.

A list of the disclosures that need to be made available to the Data Subject is provided in Appendix A.

The Cross Keys Hotel Entity collecting the information, in cooperation with the Cross Keys Hotel Management, must establish means for documenting the fact that the Data Subject already has the information and how it has been obtained.

• The ongoing administration and management of customer services.

The use of a Contact’s information should always be considered from their perspective and whether the use will be within their expectations or if they are likely to object.

For example, it would clearly be within a Contact’s expectations that their details will be used by Cross Keys Hotel to respond to a Contact request for information about the products and services on offer. However, it will not be within their reasonable expectations that Cross Keys Hotel would then provide their details to Third Parties for marketing purposes.

Each Cross Keys Hotel Entity will Process Personal Data in accordance with all applicable laws and applicable contractual obligations. More specifically, Cross Keys Hotel will not Process Personal Data unless at least one of the following requirements are met:

• The Data Subject has given Consent to the Processing of their Personal Data for one or more specific purposes.

• Processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract.

• Processing is necessary for compliance with a legal obligation to which the Data Controller is subject.

• Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person.

• 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.

• 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 interests or fundamental rights and freedoms of the Data Subject, in particular where the Data Subject is a child).

There are some circumstances in which Personal Data may be further processed for purposes that go beyond the original purpose for which the Personal Data was collected. When making a determination as to the compatibility of the new reason for Processing, guidance and approval must be obtained from the Cross Keys Hotel Management before any such Processing may commence.

In any circumstance where Consent has not been gained for the specific Processing in question, Cross Keys Hotel will address the following additional conditions to determine the fairness and transparency of any Processing beyond the original purpose for which the Personal Data was collected:

• Any link between the purpose for which the Personal Data was collected and the reasons for intended further Processing.

• The context in which the Personal Data has been collected, in particular regarding the relationship between Data Subject and the Data Controller.

• The nature of the Personal Data, in particular whether Special Categories of Data are being Processed, or whether Personal Data related to criminal convictions and offences are being processed.

• The possible consequences of the intended further Processing for the Data Subject.

• The existence of appropriate safeguards pertaining to further Processing, which may include Encryption, Anonymisation or Pseudonymisation.

5.4.2 Special Categories of Data

Cross Keys Hotel will only Process Special Categories of Data (also known as sensitive data) where the Data Subject expressly consents to such Processing or where one of the following conditions apply:

• The Processing relates to Personal Data which has already been made public by the Data Subject.

• The Processing is necessary for the establishment, exercise or defence of legal claims.

• The Processing is specifically authorised or required by law.

• The Processing is necessary to protect the vital interests of the Data Subject or of another natural person where the Data Subject is physically or legally incapable of giving consent.

• Further conditions, including limitations, based upon national law related to the processing of genetic data, biometric data or data concerning health.

In any situation where Special Categories of Data are to be processed, prior approval must be obtained from the Cross Keys Hotel Management and the basis for the processing clearly recorded with the Personal Data in question.

Where Special Categories of Data are being Processed, Cross Keys Hotel will adopt additional protection measures. Each Cross Keys Hotel Entity may also adopt additional measures to address local custom or social expectation over the processing of Special Categories of Data.

Children are unable to Consent to the Processing of Personal Data for information society services. Consent must be sought from the person who holds parental responsibility over the child. However, it should be noted that where Processing is lawful under other grounds, Consent need not be obtained from the child or the holder of parental responsibility.

Should any Cross Keys Hotel Entity foresee a business need for obtaining parental consent for information society services offered directly to a child, guidance and approval must be obtained from the Cross Keys Hotel Management before any processing of a child’s Personal Data may commence.

Each Cross Keys Hotel Entity will adopt all necessary measures to ensure that the Personal Data it collects and Processes is complete and accurate in the first instance, and is updated to reflect the current situation of the Data Subject.

The measures adopted by Cross Keys Hotel to ensure data quality include:

The age by which an individual is designated a child varies between 13 and 16 in accordance with national law.

Any service normally provided for remuneration, at a distance, by electronic means and at the individual request of a recipient of services.

• Correcting Personal Data known to be incorrect, inaccurate, incomplete, ambiguous, misleading or outdated, even if the Data Subject does not request rectification.

• Keeping Personal Data only for the period necessary to satisfy the permitted uses or applicable statutory retention period.

• The removal of Personal Data if in violation of any of the Data Protection principles or if the Personal Data is no longer required.

• Restriction, rather than deletion of Personal Data, insofar as:

• A law prohibits erasure.

• Erasure would impair legitimate interests of the Data Subject.

• The Data Subject disputes that their Personal Data is correct and it cannot be clearly ascertained whether their information is correct or incorrect.

The Cross Keys Hotel will only engage in Profiling and automated decision-making where it is necessary to enter into, or to perform, a contract with the Data Subject or where it is authorised by law.

Where a Cross Keys Hotel Entity utilises Profiling and automated decision-making, this will be disclosed to the relevant Data Subjects. In such cases the Data Subject will be given the opportunity to:

• Express their point of view.

• Obtain an explanation for the automated decision.

• Review the logic used by the automated system.

• Supplement the automated system with additional data.

• Have a human carry out a review of the automated decision.

• Contest the automated decision.

• Object to the automated decision-making being carried out.

Each Cross Keys Hotel Entity must also ensure that all Profiling and automated decision-making relating to a Data Subject is based on accurate data.

Correction may include data erase and replacement with corrected or supplemented data.

As a general rule Cross Keys Hotel will not send promotional or direct marketing material to a Cross Keys Hotel Contact through digital channels such as mobile phones, email and the Internet, without first obtaining their Consent. Any Cross Keys Hotel Entity wishing to carry out a digital marketing campaign without obtaining prior Consent from the Data Subject must first have it approved by the Cross Keys Hotel Management.

Where Personal Data Processing is approved for digital marketing purposes, the Data Subject must be informed at the point of first contact that they have the right to object, at any stage, to having their data Processed for such purposes. If the Data Subject puts forward an objection, digital marketing related Processing of their Personal Data must cease immediately and their details should be kept on a suppression list with a record of their opt-out decision, rather than being completely deleted.

It should be noted that where digital marketing is carried out in a ‘business to business’ context, there is no legal requirement to obtain an indication of consent to carry out digital marketing to individuals provided that they are given the opportunity to opt-out.

To ensure fair Processing, Personal Data will not be retained by Cross Keys Hotel for longer than necessary in relation to the purposes for which it was originally collected, or for which it was further Processed.

The length of time for which Cross Keys Hotel Entities need to retain Personal Data is set out in the Cross Keys Hotel ‘Personal Data Retention Schedule’. This takes into account the legal and contractual requirements, both minimum and maximum, that influence the retention periods set forth in the schedule. All Personal Data should be deleted or destroyed as soon as possible where it has been confirmed that there is no longer a need to retain it.

Each Cross Keys Hotel Entity will adopt physical, technical, and organisational measures to ensure the security of Personal Data. This includes the prevention of loss or damage, unauthorised alteration, access or Processing, and other risks to which it may be exposed by virtue of human action or the physical or natural environment.

The minimum set of security measures to be adopted by each Cross Keys Hotel Entity is provided in the Cross Keys Hotel ‘Information Security Policy’. A summary of the Personal Data related security measures is provided below:

• Prevent unauthorised persons from gaining access to data processing systems in which Personal Data are processed.

• Prevent persons entitled to use a data processing system from accessing Personal Data beyond their needs and authorisations.

• Ensure that Personal Data in the course of electronic transmission during transport cannot be read, copied, modified or removed without authorisation.

• Ensure that access logs are in place to establish whether, and by whom, the Personal Data was entered into, modified on or removed from a data processing system.

• Ensure that in the case where Processing is carried out by a Data Processor, the data can be processed only in accordance with the instructions of the Data Controller.

• Ensure that Personal Data is protected against undesired destruction or loss.

• Ensure that Personal Data collected for different purposes can and is processed separately.

• Ensure that Personal Data is not kept longer than necessary.

• The Cross Keys Hotel Management will establish a system to enable and facilitate the exercise of Data Subject rights related to:

• Information access.

• Objection to Processing.

• Objection to automated decision-making and profiling.

• Restriction of processing.

• Data portability.

• Data rectification.

• Data erasure.

If an individual makes a request relating to any of the rights listed above, the Cross Keys Hotel will consider each such request in accordance with all applicable Data Protection laws and regulations. No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be unnecessary or excessive in nature.

Data Subjects are entitled to obtain, based upon a request made in writing to the Cross Keys Hotel Management and upon successful verification of their identity, the following information about their own Personal Data:

• The purposes of the collection, Processing, use and storage of their Personal Data.

• The source(s) of the Personal Data, if it was not obtained from the Data Subject;

• The categories of Personal Data stored for the Data Subject.

• The recipients or categories of recipients to whom the Personal Data has been or may be transmitted, along with the location of those recipients.

• The envisaged period of storage for the Personal Data or the rationale for determining the storage period.

• The use of any automated decision-making, including Profiling.

• The right of the Data subject to:

• Object to processing of their Personal Data.

• Lodge a complaint with the Data Protection Authority.

• Request rectification or erasure of their Personal Data.

• Request restriction of Processing of their Personal Data.

All requests received for access to or rectification of Personal Data must be directed to the Cross Keys Management, who will log each request as it is received. A response to each request will be provided within 30 days of the receipt of the written request from the Data Subject. Appropriate verification must confirm that the requestor is the Data Subject or their authorised legal representative. Data Subjects shall have the right to require Cross Keys Hotel to correct or supplement erroneous, misleading, outdated, or incomplete Personal Data.

If the Cross Keys Management cannot respond fully to the request within 30 days, they will nevertheless provide the following information to the Data Subject, or their authorised legal representative within the specified time:

• An acknowledgement of receipt of the request.

• Any information located to date.

• Details of any requested information or modifications which will not be provided to the Data Subject, the reason(s) for the refusal, and any procedures available for appealing the decision.

• An estimated date by which any remaining responses will be provided.

• An estimate of any costs to be paid by the Data Subject (e.g. where the request is excessive in nature).

• The name and contact information of the Cross Keys Hotel individual who the Data Subject should contact for follow up.

It should be noted that situations may arise where providing the information requested by a Data Subject would disclose Personal Data about another individual.

In such cases, information must be redacted or withheld as may be necessary or appropriate to protect that person’s rights.

Detailed guidance for dealing with requests from Data Subjects can be found in the Cross Keys Hotel ‘Data Subject Request Handling Procedures’ document.

In certain circumstances, it is permitted that Personal Data be shared without the knowledge or Consent of a Data Subject. This is the case where the disclosure of the Personal Data is necessary for any of the following purposes:

• The prevention or detection of crime.

• The apprehension or prosecution of offenders.

• The assessment or collection of a tax or duty.

• By the order of a court or by any rule of law.

If a Cross Keys Hotel Entity Processes Personal Data for one of these purposes, then it may apply an exception to the Processing rules outlined in this policy but only to the extent that not doing so would be likely to prejudice the case in question.

If any Cross Keys Hotel Entity receives a request from a court or any regulatory or law enforcement authority for information relating to a Cross Keys Hotel Contact, you must immediately notify the Cross Keys Hotel Management who will provide comprehensive guidance and assistance.

All Cross Keys Hotel Employees that have access to Personal Data will have their responsibilities under this policy outlined to them as part of their staff induction training. In addition, each Cross Keys Hotel Entity will provide regular Data Protection training and procedural guidance for their staff.

The training and procedural guidance set forth will consist of, at a minimum, the following elements:

• The Data Protection Principles set forth in Section 5.2 above.

• Each Employee’s duty to use and permit the use of Personal Data only by authorised persons and for authorised purposes.

• The need for, and proper use of, the forms and procedures adopted to implement this policy.

• The correct use of passwords, security tokens and other access mechanisms.

• The importance of limiting access to Personal Data, such as by using password protected screen savers and logging out when systems are not being attended by an authorised person.

• Securely storing manual files, print outs and electronic storage media.

• The need to obtain appropriate authorisation and utilise appropriate safeguards for all transfers of Personal Data outside of the internal network and physical office premises.

• Proper disposal of Personal Data by using secure shredding facilities.

• Any special risks associated with particular departmental activities or duties.

Cross Keys Hotel Entities may transfer Personal Data to internal or Third Party recipients located in another country where that country is recognised as having an adequate level of legal protection for the rights and freedoms of the relevant Data Subjects.

Where transfers need to be made to countries lacking an adequate level of legal protection (i.e. Third Countries), they must be made in compliance with an approved transfer mechanism Cross Keys Hotel Entities may only transfer Personal Data where one of the transfer scenarios list below applies:

• The Data Subject has given Consent to the proposed transfer.

• The transfer is necessary for the performance of a contract with the Data Subject.

For a list of countries recognised as having an adequate level of legal protection see Appendix B.

For a list of Third Country transfer mechanisms recognised as providing adequate protection see Appendix B.

• The transfer is necessary for the implementation of pre-contractual measures taken in response to the Data Subject’s request.

• The transfer is necessary for the conclusion or performance of a contract concluded with a Third Party in the interest of the Data Subject.

• The transfer is legally required on important public interest grounds.

• The transfer is necessary for the establishment, exercise or defence of legal claims.

• The transfer is necessary in order to protect the vital interests of the Data Subject.

In order for Cross Keys Hotel to carry out its operations effectively across its various Cross Keys Hotel Entities, there may be occasions when it is necessary to transfer Personal Data from one Cross Keys Hotel Entity to another, or to allow access to the Personal Data from an overseas location. Should this occur, the Cross Keys Hotel Entity sending the Personal Data remains responsible for ensuring protection for that Personal Data.

The Cross Keys Hotel handles the transfer of Personal Data between Cross Keys Hotel Entities, where the location of the recipient Entity is a Third Country, using the Binding Corporate Rules transfer mechanism. Binding Corporate Rules provide legally binding, enforceable rights on Data Subjects with regard to the Processing of their Personal Data and must be enforced by each approved Cross Keys Hotel Entity, including their Employees.

When transferring Personal Data to another Cross Keys Hotel Entity located in a Third Country, they will:

• Ensure that the recipient Cross Keys Hotel Entity is included on the approved list of Cross Keys Hotel Entities subject to the Cross Keys Hotel ‘Binding Corporate Rules Agreement’. The approved list is held and maintained by the Cross Keys Hotel Management.

• Only transfer the minimum amount of Personal Data necessary for the particular purpose of the transfer (for example, to fulfil a transaction or carry out a particular service).

• Ensure adequate security measures are used to protect the Personal Data during the transfer (including password-protection and Encryption, where necessary).

Each Cross Keys Hotel Entity will only transfer Personal Data to, or allow access by, Third Parties when it is assured that the information will be processed legitimately and protected appropriately by the recipient. Where Third Party Processing takes place, each Cross Keys Hotel Entity will first identify if, under applicable law, the Third Party is considered a Data Controller or a Data Processor of the Personal Data being transferred.

Where the Third Party is deemed to be a Data Controller, the Cross Keys Hotel Entity will enter into, in cooperation with the Cross Keys Hotel Management, an appropriate agreement with the Controller to clarify each party’s responsibilities in respect to the Personal Data transferred.

Where the Third Party is deemed to be a Data Processor, the Cross Keys Hotel Entity will enter into, in cooperation with the Cross Keys Hotel Management, an adequate Processing agreement with the Data Processor. The agreement must require the Data Processor to protect the Personal Data from further disclosure and to only Process Personal Data in compliance with Cross Keys Hotel instructions. In addition, the agreement will require the Data Processor to implement appropriate technical and organisational measures to protect the Personal Data as well as procedures for providing notification of Personal

Cross Keys Hotel has a ‘Standard Data Processing Agreement’ document that should be used as a baseline template.

When a Cross Keys Hotel Entity is outsourcing services to a Third Party (including Cloud Computing services), they will identify whether the Third Party will Process Personal Data on its behalf and whether the outsourcing will entail any Third Country transfers of Personal Data. In either case, it will make sure to include, in cooperation with the Cross Keys Hotel Management, adequate provisions in the outsourcing agreement for such Processing and Third Country transfers. Cross Keys Hotel has a ‘Standard Provisions for Outsourcing Agreement’ document that should be used for guidance.

The Cross Keys Hotel Management shall conduct regular audits of Processing of Personal Data performed by Third Parties, especially in respect of technical and organisational measures they have in place. Any major deficiencies identified will be reported to and monitored by the Cross Keys Hotel Executive Management team.

Data Subjects with a complaint about the Processing of their Personal Data, should put forward the matter in writing to the Cross Keys Hotel Management. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case. The Cross Keys Hotel Management will inform the Data Subject of the progress and the outcome of the complaint within a reasonable period.

If the issue cannot be resolved through consultation between the Data Subject and the Cross Keys Hotel Management, then the Data Subject may, at their option, seek redress through mediation, binding arbitration, litigation, or via complaint to the Data Protection Authority within the applicable jurisdiction.

Any individual who suspects that a Personal Data Breach has occurred due to the theft or exposure of Personal Data must immediately notify the Cross Keys Hotel Management providing a description of what occurred. Notification of the incident can be made via e-mail <info@crosskeyschatteris.com>, by calling 01354 692644 or by using the reporting form at <www.crosskeyschatteris.com>.

The Cross Keys Hotel Management will investigate all reported incidents to confirm whether or not a Personal Data Breach has occurred. If a Personal Data Breach is confirmed, the Cross Keys Hotel Management will follow the relevant authorised procedure based on the criticality and quantity of the Personal Data involved.

All inquiries about this policy, including requests for exceptions or changes should be directed to the Cross Keys Management via e-mail < info@crosskeyschatteris.com >.

This policy shall be available to all Cross Keys Hotel Employees through the Cross Keys Hotel Policy Portal [held on SSID: cross-keys-mgmt].or via alternative means as deemed appropriate by the Cross Keys Hotel Management.

This policy is effective as of 25th May 2018. The date set for GDPR to become effective as EU law.

The Cross Keys Hotel Management is responsible for the maintenance and accuracy of this policy. Notice of significant revisions shall be provided to Cross Keys Hotel Employees through the Human Resources department. Changes to this policy will come into force when published on Cross Keys Hotel Policy Portal [held on SSID: cross-keys-mgmt].

Listed below are documents that relate to and are referenced by this policy:

• Internet Privacy Notice template

• Internet Cookie Notice template

• Information Security Policy

• Data Subject Request Handling Procedure

• Data Protection Policy for Employee Data

• Personal Data Retention Schedule

• Standard Data Processing Agreement

• Standard Provisions for Outsourcing Agreement

• Binding Corporate Rules Agreement

 

 

The table below outlines the various information elements that must be provided by the Data Controller to the Data Subject depending upon whether or not Consent has not been obtained from the Data Subject.

Information Requiring Notification

With Consent

Without Consent

• The identity and the contact details of the Data Controller and, where applicable, of the Data Controller’s representative.

YES

YES

• The original source of the Personal Data, and if applicable, whether it came from a publicly accessible source.

NO

YES

• The contact details of the Data Protection Officer, where applicable.

YES

YES

• The purpose(s) and legal basis for Processing the Personal Data.

YES

YES

• The categories of Personal Data concerned.

YES

YES

• The recipients or categories of recipients of the Personal Data.

YES

YES

• Where the Data Controller intends to further Process the Personal Data for a purpose other than that for which the Personal Data was originally collected, the Data Controller shall provide the Data Subject, prior to that further Processing, with information on that other purpose.

YES

YES

• Where the Data Controller intends to transfer Personal Data to a recipient in a Third Country, notification of that intention and details regarding adequacy decisions taken in relation to the Third Country must be provided.

YES

YES

• The period for which the Personal Data will be stored, or if that is not possible, the criteria used to determine that period.

YES

YES

• Where applicable, the legitimate interests pursued by the Data Controller or by a Third Party.

YES

YES

• The existence of Data Subject rights allowing them to request from the Data Controller- information access, objection to Processing, objection to automated decision-making and profiling, restriction of Processing, data portability, data rectification and data erasure.

YES

YES

• Where Processing is based on Consent, the existence of the right to withdraw Consent at any time, without affecting the lawfulness of Processing based on Consent before its withdrawal.

YES

NO

• The right to lodge a complaint with a Data Protection Authority.

YES

YES

• The existence of automated decision-making (including Profiling) along with meaningful information about the logic involved and the significance of any envisaged consequences of such Processing for the Data Subject.

YES

YES

• Whether the provision of Personal Data is a statutory or contractual requirement, a requirement necessary to enter into a contract, as well as whether the Data Subject is obliged to provide the Personal Data and if so the possible consequences of failure to provide such data.

YES

YES

 

 

 

The following are a list of countries recognised as having an adequate level of legal protection for the rights and freedoms of Data Subjects in relation to the Processing of their Personal Data.

• EU Countries

(Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the UK)

• Iceland

• Liechtenstein

• Norway

• Andorra

• Argentina

• Canada (commercial organisations)

• Faeroe Islands

• Guernsey

• Israel

• Isle of Man

• Jersey

• New Zealand

• Switzerland

• Uruguay

• United States (Privacy Shield certified organisations)

The following are a list of Third Country transfer mechanisms that can provide adequate protection when transfers are made to countries lacking an adequate level of legal protection.

Appropriate safeguards:

• Model Clauses

• Binding Corporate Rules

• Codes of Conduct

• Certification Mechanisms

• Derogations

• Explicit Consent

• Compelling Legitimate Interests

• Important reasons of Public Interest

• Transfers in response to a foreign legal requirement

• DPA approved contracts between Data Controllers and Data Processors