This Policy sets out the obligations of Alecto Recruitment Ltd (CRN: 07092830) (“Company”) regarding data protection and the rights of individuals that the Company engages with (“Data Subjects”) in respect of personal data under the General Data Protection Regulation (“Regulation”). A ‘Data Subject’ may be an individual or an individual acting on behalf of a body corporate (i.e. a company director).

The Regulation 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.This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

The data protection principles

This Policy aims to ensure compliance with the Regulation. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:

1. processed lawfully, fairly, and in a transparent manner in relation to the data subject;
2. collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
3. further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be
4. considered to be incompatible with the initial purposes;
5. adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
6. 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 they are processed, is erased or rectified without delay;
7. 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 Regulation in order to safeguard the rights and freedoms of the data subject;
8. 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.