Data protection policy

Key definitions

Data Protection Legislation: UK General Data Protection Regulation (“UK GDPR”), Data Protection Act 2018 (“DPA 2018”), Privacy and Electronic Communications Regulations 2003, and any other relevant law concerning the processing of personal data.

Data: information processed by automated or non-automated means, including structured files that are accessible by specific criteria. 

Personal data: any information that can, either directly or indirectly, identify a living person. Identifiers include:

  • name
  • address
  • date of birth
  • postcodes
  • unique identification numbers
  • location data
  • online identifiers (such as an IP address)
  • pseudonymised data
  • information relating to a person's social or economic status

Special category data: personal data consisting of information relating to:

  • race or ethnicity 
  • political opinions
  • religious beliefs or other beliefs of a similar nature
  • trade union membership or affiliation 
  • physical or mental health or condition
  • biometric and, or genetic data
  • sex life or sexual orientation

Criminal convictions data: personal data relating to:

  • the alleged commission of offences by the data subject, or
  • proceedings for an offence committed or alleged to have been committed by the data subject or the disposal of such proceedings, including sentencing.

Processing: any action on personal data, such as collection, use, storage, sharing, or destruction (whether by automated or manual means).

Data subject: the individual whose data is being processed.

Controller: the person or organisation that decides (either alone or jointly with others) how and why personal data is processed.

Processor: any person or organisation that processes data on behalf of the controller.

Law enforcement processing: processing personal data for the purpose of:

  • the prevention, investigation, detection or prosecution of criminal offences, or
  • the execution of criminal penalties, including protecting and preventing threats to public security