Data Protection Policy Statement

The Curious Companions LLP is fully committed to full compliance with the requirements of the General Data Protection Regulation (GDPR). Regulations apply to anyone processing personal data. It sets out principles which should be followed and it also gives rights to those whose data is being processed. The Curious Companions LLP therefore follow procedures which aim to ensure that all employees, subcontractors and other partners (collectively known as data users) who have access to any personal data held by or on behalf of The Curious Companions LLP are fully aware of and abide by their duties under the General Data Protection Regulation.

Statement of Policy

The Curious Companions LLP needs to collect and use information about people with whom it works in order to operate and carry out its functions. These may include members of the public, prospective employees, clients and suppliers. This personal information must be handled and dealt with properly however it is collected, recorded and used and whether it is on paper, in computer records or recorded by other means. The Curious Companions LLP regards the lawful and appropriate treatment of personal information as very important to its successful operations and essential to maintaining confidence between The Curious Companions LLP and those with whom it carries out business. The Curious Companions LLP therefore fully endorses and adheres to the Principles of the General Data Protection Regulation.

Handling personal/special category data

The Curious Companions LLP will, through management and use of appropriate controls, monitoring and review:

o Use personal data in the most efficient and effective way to deliver better services and products

o Strive to collect and process only the data or information which is needed

o Use personal data for such purposes as are described at the point of collection, or for purposes which are legally permitted

o Strive to ensure information is accurate

o Not keep information for longer than is necessary

o Securely destroy data which is no longer needed

o Take appropriate technical and organisational security measures to safeguard information (including unauthorised or unlawful processing and accidental loss or damage of data)

o Ensure that there is general information made available to the public of their rights to access information

o Ensure that the rights of people about whom information is held can be fully exercised under the General Data Protection Regulation. These rights include:

- The right to be informed

- The right of access to personal information

- The right to request rectification

- The right to request erasure

- The right to restrict processing in certain circumstances

- The right to data portability

- The right to object to processing

The Principles of Data Protection

Anyone processing personal data must comply with 6 principles of good practice. These principles are legally enforceable. Summarised, the principles require that personal data shall be:

1. Processed lawfully, fairly and in a transparent manner in relation to individuals.

2. Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.

3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

4. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.

5. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are 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 GDPR in order to safeguard the rights and freedoms of individuals.

6. 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.

Accordance with the rights of data subjects under the Act

The Act provides conditions for the processing of any personal data. It also makes a distinction between personal data and 'special category' data. Personal data is defined as any information relating to an identified or identifiable natural person. Special category data is defined as personal data consisting of information as to:

o Racial or ethnic origin

o Political opinion

o Religious/philosophical beliefs

o Trade union membership

o Physical or mental health or condition

o Sexual life or sexual orientation

o Biometric data

The Curious Companions LLP will not be processing or holding any special category data. Personal data will only be collected and stored in accordance with the lawful basis of processing personal data as outlined by the ICO (Information Commissioner's Office): either with consent, for contract fulfilment purposes, or under legitimate interests.

Points of contact for any data protection issues are Dan Severn and Emma Northover.