Your privacy is important to us at DOYLE CHAMBERS. To better protect your privacy we provide
this notice explaining our online information practices and the choices you can make about the way your
information is collected and used. You agree to agree to these policies by virtue of using our website in a
way that leads to you providing us with personal information.
State Law & Accompanying Rights
Please understand that you may have additional rights originating from State laws based on
where you live. These State-based rights may augment, strengthen, or otherwise somehow compliment any privacy
rights you have inherently or under Federal law. Our policy is to comply fully with the privacy policies of
every jurisdiction in which we operate. Accordingly, you are free to use our Contact information to reach us
at any time to assert any State rights.
Our Commitment To Children’s Privacy
Protecting the privacy of the very young is especially important. For that reason, our website
will never collect or maintain information at our website from those we actually know are under 18, and no
part of our website is structured to attract anyone under 18.
Under our Terms of Service and Conditions of Use, children under 18 are not allowed to use our
website and access our services. It is not our intention to offer products or services to minors.
Collection of Personal Information
When visiting our website, the IP address used to access our website may be logged along with
the dates and times of access. This information is purely used to analyze trends, administer our website,
track users movement, and gather broad demographic information for internal use such as statistical
assessments and website improvement. Most importantly, any recorded IP addresses are not linked to personally
Other information may be collected as well by DOYLE CHAMBERS, which is rather typical of most
websites. For instance, the source that referred you to our website is generally known. Likewise, your
duration on our website, and your destination when you leave our website can also be tracked. Other common
data collected includes the type of operating system the computer you are using to access our website has.
Similarly, the type of web browser is often noted. Again, this is common data collection, and helps
ultimately produce a better end-user experience.
Cookies are another common internet practice. Cookies are a key means of improving user
experience by allows us to customize your use of our website. Simple information is transferred to your
computer to allow the content and experience at DOYLE CHAMBERS to reflect your actions, preferences, and so
adjustments in your web browser to disable these or otherwise receive notification of cookies so you can take
whatever desired action you so choose. Please understand that refusing cookies may cripple some of our
website features and render some aspects useless to you.
At times, you will be fully aware of information received, as you are the direct source
providing it. For instance, you may comment on a blog post, reply to an email (whether broadcast message or
autoresponder), provide an email address, complete a survey, requests SMS, or otherwise. Likewise, purchases
necessarily involve collecting certain information, such as credit card information, Paypal addresses, your
physical address for billing and/or shipping, phone number, and so on. Refusing to provide some of this
information may lead to us being unable to provide you with the products or services you’ve
A prime example of limited access to our website is where some DOYLE CHAMBERS content may be
protected by a username and password. Whether a username and password is generated by our website, or created
by you, these will almost always be connected with some other information related to or connected with you.
This is true since much content that is protected on the internet is subscription based, often paid for.
Thus, the username and password must necessarily be tied to your other account data. Usernames and passwords,
by their very nature, should be kept private.
Handling of Personal Information
Note that any personal information you provide to others apart from us or our vendors is
wholly optional. As an example, you might disclose something in a blog post comment. That “private”
information is now “public,” and we have no control over that. In like fashion, you sharing information with
any other third party not functioning as a service provider to us puts that information beyond our control
and becomes subject to the policy that party has in place.
Our primary intention for collecting personal and private information from you is simply to
conduct our business. We can use this internally to better serve you. Accordingly, we see no reason to share
your personal information to other parties and outside interests unless you have authorized us to do so. Of
course, there are instances where your information is stored with third party service providers, such as
email service providers, as they provide services that are industry-leading in quality and security and are
far more beneficial to our end user than attempting such services “in-house.” However, you are never required
to deal with any such third party directly, they are limited in how they use your information, and they
cannot sell or transfer it to others in any way.
However, of course, your information does comprise part of an overall whole. This aggregate of
information, by contrast, may be used to understand our overall user base. Further, we may share this
information about our website visitors as a whole, not individually, with third parties for various purposes,
in our sole discretion.
While we are staunch privacy advocates at DOYLE CHAMBERS, there are times when even we may be
forced to abandon these ideals. Just as major search engines face ongoing compulsion to provide data against
their will, so too may the same occur with our DOYLE CHAMBERS website. Illegal activity or other serious acts
or allegations could create legal liability for our website. In those cases, we reserve the right to share
your information, or else may simply be compelled to do so by law. On the other hand, there may be times when
we would need to share your private information in order to protect our own interests. For instance, in cases
of suspected or alleged copyright infringement or other intellectual property violations, it may be necessary
to share personal information.
Google Adsense and the DoubleClick DART Cookie
CHAMBERS website. The use of DART cookies by Google enables them to serve adverts to visitors that are based
on their visits to this website as well as other websites on the internet.
at the following url http://www.google.com/privacy_ads.html Tracking of users through the DART cookie
mechanisms are subject to Google’s own privacy policies.
this website to measure advertisement effectiveness and other reasons that will be provided in their own
privacy policies, our website has no access or control over these cookies that may be used by third party
Links to Third Party Websites
We have included links on this website for your use and reference. We are not responsible for
the privacy policies on these websites. You should be aware that the privacy policies of these websites may
differ from our own.
CHANGE NOTICE: As with any of our administrative and legal notice pages, the contents of this
page can and will change over time. Accordingly, this page could read differently as of your very next visit.
These changes are necessitated, and carried out by DOYLE CHAMBERS, in order to protect you and our DOYLE
CHAMBERS website. If this page is important to you, you should check back frequently as no other notice of
changed content will be provided either before or after the change takes effect.
COPYRIGHT WARNING: The legal notices and administrative pages on this website, including this
one, have been diligently drafted by an attorney. We at DOYLE CHAMBERS have paid to license the use of these
legal notices and administrative pages on DOYLE CHAMBERS for your protection and ours. This material may not
be used in any way for any reason and unauthorized use is policed via Copyscape to detect
QUESTIONS/COMMENTS/CONCERNS: If you have any questions about the contents of this page, or
simply wish to reach us for any other reason, you may do so by using our Contact information.
DoyleChambers.com strives to offer its visitors the many advantages of Internet
technology and to provide an interactive and personalized experience. We may use Personally Identifiable
Information (your name, e-mail address, street address, telephone number) subject to the terms of this
How we gather information from users
How we collect and store information depends on the page you are visiting, the
activities in which you elect to participate and the services provided. For example, you may be asked to
provide information when you register for access to certain portions of our site or request certain features,
such as newsletters or when you make a purchase. You may provide information when you participate in
sweepstakes and contests, message boards and chat rooms, and other interactive areas of our site. Like most
Web sites, DoyleChambers.com also collects information automatically and through the use of electronic tools
that may be transparent to our visitors. For example, we may log the name of your Internet Service Provider
or use cookie technology to recognize you and hold information from your visit. Among other things, the
cookie may store your user name and password, sparing you from having to re-enter that information each time
you visit, or may control the number of times you encounter a particular advertisement while visiting our
site. As we adopt additional technology, we may also gather information through other means. In certain
cases, you can choose not to provide us with information, for example by setting your browser to refuse to
accept cookies, but if you do you may be unable to access certain portions of the site or may be asked to
re-enter your user name and password, and we may not be able to customize the site’s features according to
What we do with the information we collect
Like other Web publishers, we collect information to enhance your visit and deliver
more individualized content and advertising. We respect your privacy and do not share your information with
Aggregated Information (information that does not personally identify you) may be used
in many ways. For example, we may combine information about your usage patterns with similar information
obtained from other users to help enhance our site and services (e.g., to learn which pages are visited most
or what features are most attractive). Aggregated Information may occasionally be shared with our advertisers
and business partners. Again, this information does not include any Personally Identifiable Information about
you or allow anyone to identify you individually.
We may use Personally Identifiable Information collected on DoyleChambers.com to
communicate with you about your registration and customization preferences; our Terms of Service and privacy
policy; services and products offered by DoyleChambers.com and other topics we think you might find of
Personally Identifiable Information collected by DoyleChambers.com may also be used
for other purposes, including but not limited to site administration, troubleshooting, processing of
e-commerce transactions, administration of sweepstakes and contests, and other communications with you.
Certain third parties who provide technical support for the operation of our site (our Web hosting service
for example) may access such information. We will use your information only as permitted by law. In addition,
from time to time as we continue to develop our business, we may sell, buy, merge or partner with other
companies or businesses. In such transactions, user information may be among the transferred assets. We may
also disclose your information in response to a court order, at other times when we believe we are reasonably
required to do so by law, in connection with the collection of amounts you may owe to us, and/or to law
enforcement authorities whenever we deem it appropriate or necessary. Please note we may not provide you with
notice prior to disclosure in such cases.
Affiliated sites, linked sites and advertisements
DoyleChambers.com expects its partners, advertisers and affiliates to respect the
privacy of our users. Be aware, however, that third parties, including our partners, advertisers, affiliates
and other content providers accessible through our site, may have their own privacy and data collection
policies and practices. For example, during your visit to our site you may link to, or view as part of a
frame on a DoyleChambers.com page, certain content that is actually created or hosted by a third party. Also,
through DoyleChambers.com you may be introduced to, or be able to access, information, Web sites, features,
contests or sweepstakes offered by other parties. DoyleChambers.com is not responsible for the actions or
policies of such third parties. You should check the applicable privacy policies of those third parties when
providing information on a feature or page operated by a third party.
While on our site, our advertisers, promotional partners or other third parties may
you. For example, some of our advertising is served by third parties and may include cookies that enable the
advertiser to determine whether you have seen a particular advertisement before. Other features available on
information. DoyleChambers.com does not control the use of this technology by third parties or the resulting
information, and is not responsible for any actions or policies of such third parties.
You should also be aware that if you voluntarily disclose Personally Identifiable
Information on message boards or in chat areas, that information can be viewed publicly and can be collected
and used by third parties without our knowledge and may result in unsolicited messages from other individuals
or third parties. Such activities are beyond the control of DoyleChambers.com and this policy.
DoyleChambers.com does not knowingly collect or solicit Personally Identifiable
Information from or about children under 13 except as permitted by law. If we discover we have received any
information from a child under 13 in violation of this policy, we will delete that information immediately.
If you believe DoyleChambers.com has any information from or about anyone under 13, please contact us at the
address listed below.
We can be reached by contacting:
Changes to this Policy
DoyleChambers.com reserves the right to change this policy at any time. Please check
this page periodically for changes. Your continued use of our site following the posting of changes to these
terms will mean you accept those changes. Information collected prior to the time any change is posted will
be used according to the rules and laws that applied at the time the information was collected.
This policy and the use of this Site are governed by Texas law. If a dispute arises
under this Policy we agree to first try to resolve it with the help of a mutually agreed-upon mediator in the
following location: Hunt. Any costs and fees other than attorney fees associated with the mediation will be
shared equally by each of us.
If it proves impossible to arrive at a mutually satisfactory solution through
mediation, we agree to submit the dispute to binding arbitration at the following location: Hunt County,
under the rules of the American Arbitration Association. Judgment upon the award rendered by the arbitration
may be entered in any court with jurisdiction to do so.
DoyleChambers.com is controlled, operated and administered entirely within Texas. This
statement and the policies outlined herein are not intended to and do not create any contractual or other
legal rights in or on behalf of any party.
Cookies on Doyle Chambers websites:
Cookies are small text files stored on your device when you access most websites on
support the provision of information and functionality to you, as well as to provide us with information about
how Doyle Chambers websites is used so that we can make sure it is as up to date, relevant and error free as we
restrict or block cookies set on Doyle Chambers websites through your browser settings at any time. For more
information about how to do this, and about cookies in general, you can visit www.allaboutcookies.org . Please note that certain cookies
may be set as soon as you visit this website, but you can remove them using your browser
settings. However, please be aware that restricting or blocking cookies set on Doyle Chambers
websites may impact the functionality or performance of the Doyle Chambers websites, or prevent you from using
certain services provided through Doyle Chambers websites. It will also affect our ability to update Doyle
Chambers websites to cater for user preferences and improve performance.
Due to certain Email Subscriber Laws, Doyle Chambers'
Email Subscriber List is expressly only for United States Of America residents. If you reside outside of the United
States Of America, then do not subscribe to Doyle Chambers' Email Subscriber
List. If European Union (EU) residents or any other foreign country residents
knowingly or mistakenly subscribe to Doyle Chambers' Email Subscriber List, it is their sole
responsibility to immediately opt out or request that their data be deleted
entirely from Doyle Chambers' email subscriber list via
Doyle Chambers understands that your privacy is
important to you and that you care about how your information is used and shared online. We respect and value the
privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you
and in a manner consistent with your rights and Our obligations under the law.
This Policy applies to Our use of any and all data
Definitions and Interpretation
In this Policy the following terms shall have the
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your
computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our
Site. Details of the Cookies used by Our Site are set out in section 12, below;
“Our Site” means Doyle Chambers' main website, www.doylechambers.com,
and all other websites owned by Doyle Chambers;
“Australia and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC
Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and “We/Us/Our” means Doyle Chambers, a company in
the United States Of America, whose registered address is, 9737 CR 2434, Royse City, TX 75189,
Information About Us
“Our Site” means Doyle Chambers' main website,
www.doylechambers.com, and all other websites owned by Doyle Chambers.
Our data protection officer is Doyle Chambers who can be contacted at firstname.lastname@example.org
Scope – What Does This Policy
Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or
whether they are shared by other users). We have no control over how your data is collected, stored or used by
other websites and We advise you to check the privacy policies of any such websites before providing any data to
What Data Do We Collect?
Some data will be collected automatically by Our
voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing
up for an Account. Depending upon your use of Our Site, We may collect some or all of the following
date of birth;
contact information such as email addresses and telephone numbers;
demographic information such as post code, preferences and interests;
financial information such as credit / debit card numbers;
IP address (automatically collected);
web browser type and version (automatically collected);
operating system (automatically collected);
a list of URLs starting with a referring site, your activity on Our Site, and the site you exit
to (automatically collected);
How Do We Use Your Data?
All personal data is stored securely in accordance with the EU General
Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6,
We use your data to provide the best possible products and services to
you. This includes:
Providing and managing your Account;
Providing and managing your access to Our
Personalising and tailoring your experience on
Supplying Our products and services to you;
Personalising and tailoring Our products and
services for you;
Responding to communications from you;
Supplying you with email newsletters that you
have subscribed to (you may unsubscribe or opt-out at any time by using the provided unsubscribe link at the footer
of every email newsletter sent.
Analysing your use of Our Site and gathering
feedback to enable Us to continually improve Our Site and your user experience;]
In some cases, the collection of data may be a statutory or contractual
requirement, and We will be limited in the products and services We can provide you without your consent for Us to
be able to use such data.
With your permission and/or where permitted by law, We may also use your
data for marketing purposes which may include contacting you by email with information, news and offers on Our
products and services. We will not, however, send you any unsolicited marketing or spam and will take all
reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the
Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
Advertisers whose content appears on Our Site may engage in what is
known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity.
Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used
in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of
such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not
remove the advertising, but it will make it less relevant to your interests and activities on Our Site.
Under GDPR we will ensure that your personal data is processed lawfully,
fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at
least one of the following basis applies:
you have given consent to the processing of your
personal data for one or more specific purposes;
processing is necessary for the performance of a
contract to which you are a party or in order to take steps at the request of you prior to entering into a
processing is necessary for compliance with a
legal obligation to which we are subject;
processing is necessary to protect the vital
interests of you 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 controller;
processing is necessary for the purposes of the
legitimate interests pursued by us or by a third party, except where such interests are overridden by the
fundamental rights and freedoms of the data subject which require protection of personal data, in particular where
the data subject is a child.
How and Where Do We Store Your Data?
We only keep your data for as long as We need to in order to use it as
described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will
conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer
need it in accordance with the terms of our Data Retention Policy
Some or all of your data may be stored or transferred outside of the
European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and
Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If
We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated
as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited
to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the
EU-approved Model Contractual Arrangements.
Data security is of great importance to Us, and to protect your data We
have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected
through Our Site.
Steps We take to secure and protect your data include:
Using 256-bit encryption technology on our
storage systems that are password protected.
Notwithstanding the security measures that We take, it is important to
remember that the transmission of data via the internet may not be completely secure and that you are advised to
take suitable precautions when transmitting to Us data via the internet.
Do We Share Your Data?
We may share your data with other companies in Our group. This includes
Our subsidiaries and Our holding company and its subsidiaries.
We may compile statistics about the use of Our Site including data on
traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not
include any personally identifying information. We may from time to time share such data with third parties such as
prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of
In certain circumstances We may be legally required to share certain
data held by Us, which may include your personal information, for example, where We are involved in legal
proceedings, where We are complying with the requirements of legislation, a court order, or a governmental
authority. We do not require any further consent from you in order to share your data in such circumstances and
will comply as required with any legally binding request that is made of Us.
What Happens If Our Business Changes Hands?
We may, from time to time, expand or reduce Our business and this may
involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where
it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or
for which it was originally collected by Us.
In the event that any of your data is to be transferred in such a
manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice
to have your data deleted or withheld from the new owner or controller.
How Can You Control Your Data?
When you submit information via Our Site, you may be
given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data
(including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links
provided in Our emails and at the point of providing your details and by managing your Account).
Your Right to Withhold Information
and Your Right to Withdraw Information After You Have Given it
You may access Our Site without providing any data at all. However, to
use all features and functions available on Our Site you may be required to submit or allow for the collection of
information, see section 12.
You may withdraw your consent for Us to use your personal data as set
out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your
data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products
and services to you.
How Can You Access Your Data?
You have the legal right to ask for a copy of any of
your personal data held by Us (where such data is held). Please contact Us for more details at email@example.com or using the contact details below
in section 14. Alternatively, please refer to Our Data Protection Policy -
What Cookies Do We Use and What For?
Our Site may place and access certain first party Cookies on your
computer or device. First party
Cookies are those placed directly by Us and are used
products and For more details, please refer to section 5, above, and to section 12.6 below. We have carefully
chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.
By using Our Site you may also receive certain third party Cookies on
your computer or device.
Third party Cookies are those placed by websites,
services, and/or parties other than Us. We use third party Cookies on Our Site for advertising services. For more
details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the
functioning of Our Site.
All Cookies used by and on Our Site are used in accordance with current
English and EU Cookie
Before any Cookies are placed on your computer or device, subject to
section 12.5 and section
12.8, you will be shown a message bar requesting your
consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the
best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however
certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Australia
and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6.
Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet
browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended
if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following third party Cookies may be placed on your computer or
Name of Cookie Provider Purpose
Facebook Ads pixel Facebook Facebook & Instagram Retargeting Ads
Intercom Intercom Customer on-boarding
Our Site uses analytics services
provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage
statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site
and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed
below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does
enable Us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us
to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps
set out below in section 12.10.
The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie First / Third Party Provider Purpose
Google Analytics Third Party Google Website analytics
You can choose to enable or
disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to
disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be
changed. For further details, please consult the help menu in your internet browser or the documentation that came
with your device.
You can choose to delete Cookies at any time however you may lose any information that enables
you to access Our Site more quickly and efficiently including, but not limited to, login and
It is recommended that you keep your internet browser and operating system up-to-date and that
you consult the help and guidance provided by the developer of your internet browser and manufacturer of your
computer or device if you are unsure about adjusting your privacy settings.
Summary of Your Rights under
Under the GDPR, you have:
the right to request access to,
deletion of or correction of, your personal data held by Us;
the right to complain to a supervisory authority;
be informed of what data processing is taking place;
the right to restrict processing;
the right to data portability;
object to processing of your personal data;
rights with respect to automated decision-making and profiling (see section 14
To enforce any of the foregoing rights or if you have
Automated Decision-Making and
14.1 In the event that We use personal
data for the purposes of automated decision-making and those
decisions have a legal (or similarly significant
effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention,
expressing their own point of view, and obtaining an explanation of the decision from Us.
14.2 The right described in section 14.1 does not
apply in the following circumstances:
The decision is necessary for the
entry into, or performance of, a contract between the You and Us;
The decision is authorised by law; or
You have given us explicit consent.
Where We use your personal data
for profiling purposes, the following shall apply:
Clear information explaining the profiling will be provided, including
its significance and the likely consequences;
Appropriate mathematical or statistical procedures will be used;
Technical and organisational measures necessary to minimise the risk of
errors and to enable such errors to be easily corrected shall be implemented; and
All personal data processed for profiling purposes shall be secured in
order to prevent discriminatory effects arising out of profiling.
If you have any questions about Our Site or this
particularly if it is a request for information about the data We hold about you (as under section 11,
Changes to Our Privacy
necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and
alterations. We recommend that you
check this page regularly to keep
Data Retention Policy
This data retention policy sets out the obligations of Unstoppable Profits Pty Ltd (“us/we/our”) and the basis
upon which we shall retain, review and destroy data held by us, or within our custody or control.
This policy applies to our entire organisation including our officers, employees, agents and sub-contractors and
sets out what the retention periods are and when any such data may be deleted.
It is necessary to retain and process certain information to enable our business to operate. We may store
data in the following places:
our own servers;
any third party servers;
potential email accounts;
employee-owned devices (BYOD);
potential backup storage; and/or
our paper files.
This policy applies equally to paper, electronic media and any other method used to store personal data.
The period of retention only commences when the record is closed.
We are bound by various obligations under the law in relation to this and therefore, to comply with the law,
information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully in
respect of their personal data under the General Data Protection Regulation (“the Regulation”).
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 and how we aim to
comply with the Regulation in so far as it is possible. In summary, the Regulation states that all personal data
processed lawfully, fairly, and in a transparent manner in relation to the data subject;
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;
adequate, relevant and limited to what is necessary in relation to the purposes for which it is
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;
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;
processed in a manner that ensures appropriate security of the personal data, including
against unauthorised or unlawful processing and against accidental loss, destruction or damage, using
appropriate technical or organisational measures.
The Fourth and Fifth Data Protection Principles require that any data should not be kept longer than necessary
for the purpose for which it is processed and when it is no longer required, it shall be deleted and that the data
should be adequate, relevant and limited for the purpose in which it is processed.
With this in mind, this policy should be read in conjunction with our other policies which are relevant such as
our data protection policy and IT security policy.
Security and Storage
All data and records are stored securely to avoid misuse or loss. We will take appropriate security measures
against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to,
We will put in place procedures and technologies to maintain the security of all personal data from the point of
collection to the point of destruction. Personal data will only be transferred to a data processor if there is
agreement by them to comply with those procedures and policies, or if there are adequate measures in place.
We will maintain data security by protecting the confidentiality, integrity and availability of the personal
data, defined as follows:
(a) Confidentiality means that only people who are authorised to use the data can access it.
(b) Integrity means that personal data should be accurate and suitable for the purpose for which it is
(c) Availability means that authorised users should be able to access the data if they need it for authorised
purposes. Personal data should therefore be stored on the company’s cloud storage instead of individual PCs.
Data retention is defined as the retention of data for a specific period of time and for back up purposes.
We shall not keep any personal data longer than necessary, but acknowledge that this will be dependent on the
different types of documents and data that we have responsibility for. As such, our general data retention period
shall be for a period of four years. Our specific data retention periods are set out below.
Type of data Type of data subject Type of processing Purpose of processing Type of
recipient to whom personal data is transferred Retention period Data accuracy and minimisation review
Customers Individual Automated Marketing, accounting Data processors 4
May 21st 2019
From time to time, it may be necessary to retain or access historic personal data under certain circumstances
such as if we have contractually agreed to do so or if we have become involved in unforeseen events like litigation
or business disaster recoveries.
Destruction and Disposal
Upon expiry of our retention periods, we shall delete confidential or sensitive records categorised as requiring
high protection and very high protection, and we shall either delete or anonymise less important documents.
Our Manager is responsible for the continuing process of identifying the records that have met their required
retention period and supervising their destruction. The destruction of confidential, financial, and
personnel-related records shall be securely destroyed electronically or by shredding if possible.
Non-confidential records may be destroyed by recycling.
Data Protection Policy
Table of Contents
Section A: Overview.......................2
Section B: Data Protection Principles.............5
Section C: Data Subject Rights..................7
Section D: Our Other Obligation................12
Schedule 1: Our Use Of Personal Data And Our Purpose....................15
Schedule 2: Our Specific Data Protection Measures................16
This Policy has been approved and authorised by:
Name: Doyle Chambers
Date: May 21st, 2018
Due Every Year for Review.
Section A: Overview
The reason for this policy
You have legal rights with regard to the way your personal data is
In the course of our business activities we collect, store and process
personal data about our customers, suppliers and other third parties, and therefore in order to comply with the law
and to maintain confidence in our business, we acknowledge the importance of correct and lawful treatment of this
All people working in or with our business are obliged to comply with
this policy when processing personal data.
This policy and any other documents referred to in it sets out the basis
on which we will process any personal data we collect from data subjects, for example, customers and business
contacts, or that is provided to us by data subjects or other sources.
It also sets out our obligations in relation to data protection under
the General Data Protection Regulation (“the Regulation”).
This policy sets out rules on data protection and the legal conditions
that must be satisfied when we obtain, handle, process, transfer and store personal data.
The procedures and principles set out herein must be followed at all
times by us and our employees, agents, contractors, or other parties working on behalf of the Company.
We aim to ensure the correct, lawful, and fair handling of your personal
data and to respect your legal rights.
The meaning of key Data Protection terms
Data is information which is stored electronically, on a computer, or in
certain paper-based filing systems.
Data subjects for the purpose of this policy include all living
individuals about whom we holds personal data. A data subject need not be a UK national or resident. All data
subjects have legal rights in relation to their personal information.
Personal data means data relating to a living individual who can be
identified from that data (or from that data and other information in our possession). Personal data can be factual
(for example, a name, address or date of birth) or it can be an opinion about that person, their actions and
Data controllers are the people who or organisations which determine the
purposes for which, and the manner in which, any personal data is processed. They are responsible for establishing
practices and policies in line with the Act. We are the data controller of all personal data used in our business
for our own commercial purposes.
Processing is any activity that involves use of the data. It includes
obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including
organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes
transferring personal data to third parties.
Summary of 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:
(Processed fairly and lawfully) processed lawfully, fairly, and in a transparent manner in
relation to the data subject;
(Processed for limited purposes and in an appropriate way) 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;
(Adequate, relevant and not excessive for the purpose) adequate, relevant and limited to what is
necessary in relation to the purposes for which it is processed;
(Accurate) 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;
(Not kept longer than necessary for the purpose) 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;
(Processing in line with data subject's rights) personal data must be processed in line with
data subjects' rights, in particular your right to:
request access to any data held about them by a Data Controller (see
also clause 15).
prevent the processing of their data for direct-marketing purposes.
ask to have inaccurate data amended (see also clause 9).
prevent processing that is likely to cause damage or distress to
themselves or anyone else.
(Security) 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.
(Transfers outside EEA) not transferred to people or organisations situated in countries without
Our use of personal data and our purpose
We collect, hold, and process the personal data referred to in Schedule 1 (and the purpose for which we process
that personal data is also set out in Schedule 1).
Our data protection measures
When we are working with personal data we take the measures set out in Schedule 2.
Section B: Data Protection Principles
Lawful, Fair, and Transparent Data Processing
The Regulation is not intended to prevent the processing of personal data, but to ensure that it is done fairly
and without adversely affecting the rights of the data subject. The processing of personal data is lawful if one
(or more) of the following applies:
(consent) the data subject has given consent to the processing of his or her personal data
for one or more specific purposes;
(contract) processing is necessary for the performance of a contract to which the data subject
is a party or in order to take steps at the request of the data subject prior to entering into a contract;
(legal obligation) processing is necessary for compliance with a legal obligation to which the
Data Controller is subject;
(protection) processing is necessary to protect the vital interests of the data subject or of
another natural person;
(public interest) 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;
(legitimate interests) 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 fundamental
rights and freedoms of the data subject which require protection of personal data, in particular where the data
subject is a child.
Processed for Specified, Explicit and Legitimate Purposes
The Company collects and processes the personal data set out in Schedule
1 of this Policy. This may include personal data received directly from data subjects (for example, contact details
used when a data subject communicates with us) and can include data received from third parties.
The Company only processes personal data for the specific purposes set
out in Schedule 1 of this Policy (or for other purposes expressly permitted by the Regulation). The purposes for
which we process personal data will be informed to data subjects at the time that their personal data is collected,
where it is collected directly from them, or as soon as possible (not more than one calendar month) after
collection where it is obtained from a third party.
Adequate, Relevant and Limited Data Processing
The Company will only collect and process personal data for and to the extent necessary for the specific
purpose(s) informed to data subjects as under Part 5, above.
Accuracy of Data and Keeping Data Up To Date
The Company shall ensure that all personal data collected and processed is kept accurate and up-to-date.
The accuracy of data shall be checked when it is collected and at regular thereafter. Where any inaccurate or
out-of-date data is found, all reasonable steps will be taken without delay to amend or erase that data, as
The Company shall not keep personal data for any longer than is necessary in light of the purposes for which
that data was originally collected and processed. When the data is no longer required, all reasonable steps will be
taken to erase it without delay.
The Company shall ensure that all personal data collected and processed is kept secure and protected against
unauthorised or unlawful processing and against accidental loss, destruction or damage. Further details of the data
protection and organisational measures which shall be taken are provided in Parts 22 and 23 of this Policy.
An assessment of the risks posed to individual data subjects; and
Details of the measures in place to minimise and handle risks including safeguards, data
security, and other measures and mechanisms to ensure the protection of personal data, sufficient to demonstrate
compliance with the Regulation.
Section C: Data Subject Rights
The Rights of Data Subjects
The Regulation sets out the following rights applicable to data subjects:
The right to be informed;
The right of access;
The right to rectification;
The right to erasure (also known as the ‘right to be forgotten’);
The right to restrict processing;
The right to data portability;
The right to object;
Rights with respect to automated decision-making and profiling.
Keeping Data Subjects Informed
The Company shall ensure that the following information is provided to
every data subject when personal data is collected:
Details of the Company including, but not
limited to, the identity of Doyle Chambers its Data Protection Officer;
The purpose(s) for which the personal data is
being collected and will be processed (as detailed in Schedule 1 of this Policy) and the legal basis justifying
that collection and processing;
Where applicable, the legitimate interests upon
which the Company is justifying its collection and processing of the personal data;
Where the personal data is not obtained directly
from the data subject, the categories of personal data collected and processed;
Where the personal data is to be transferred to
one or more third parties, details of those parties;
Where the personal data is to be transferred to
a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer,
including but not limited to the safeguards in place (see Part 26 of this Policy for further details concerning
such third country data transfers);
Details of the length of time the personal data
will be held by the Company (or, where there is no predetermined period, details of how that length of time will be
Details of the data subject’s rights under the
Details of the data subject’s right to withdraw
their consent to the Company’s processing of their personal data at any time;
Details of the data subject’s right to complain
to the Information Commissioner’s Office (the ‘supervisory authority’ under the Regulation);
Where applicable, details of any legal or
contractual requirement or obligation necessitating the collection and processing of the personal data and details
of any consequences of failing to provide it;
Details of any automated decision-making that
will take place using the personal data (including but not limited to profiling), including information on how
decisions will be made, the significance of those decisions and any consequences.
The information set out above in Part 14.1 shall be provided to the data
subject at the following applicable time:
Where the personal data is obtained from the
data subject directly, at the time of collection;
Where the personal data is not obtained from the
data subject directly (i.e. from another party):
If the personal data is
used to communicate with the data subject, at the time of the first communication; or
If the personal data is
to be disclosed to another party, before the personal data is disclosed; or
In any event, not more
than one month after the time at which the Company obtains the personal data.
Data Subject Access
A data subject may make a subject access request (“SAR”) at any time to
find out more about the personal data which the Company holds about them. The Company is normally required to
respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or
numerous requests, and in such cases the data subject shall be informed of the need for the extension).
All subject access requests received must be forwarded to Doyle
Chambers, the Company’s data protection officer. Email: firstname.lastname@example.org.
The Company does not charge a fee for the handling of normal SARs. The
Company reserves the right to charge reasonable fees for additional copies of information that has already been
supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such
requests are repetitive.
Rectification of Personal Data
If a data subject informs the Company that personal data held by the
Company is inaccurate or incomplete, requesting that it be rectified, the personal data in question shall be
rectified, and the data subject informed of that rectification, within one month of receipt the data subject’s
notice (this can be extended by up to two months in the case of complex requests, and in such cases the data
subject shall be informed of the need for the extension).
In the event that any affected personal data has been disclosed to third
parties, those parties shall be informed of any rectification of that personal data.
Erasure of Personal Data
Data subjects may request that the Company erases the personal data it
holds about them in the following circumstances:
It is no longer necessary for the Company to
hold that personal data with respect to the purpose for which it was originally collected or processed;
The data subject wishes to withdraw their
consent to the Company holding and processing their personal data;
The data subject objects to the Company holding
and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue
doing so) (see Part 20 of this
Policy for further details concerning data subjects’ rights to object);
The personal data has been processed
The personal data needs to be erased in order
for the Company to comply with a particular legal obligation.
Unless the Company has reasonable grounds to refuse to erase personal
data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one
month of receipt of the data subject’s request (this can be extended by up to two months in the case of complex
requests, and in such cases the data subject shall be informed of the need for the extension).
In the event that any personal data that is to be erased in response to
a data subject request has been disclosed to third parties, those parties shall be informed of the erasure (unless
it is impossible or would require disproportionate effort to do so).
Restriction of Personal Data Processing
Data subjects may request that the Company ceases processing the
personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount
of personal data pertaining to that data subject that is necessary to ensure that no further processing of their
personal data takes place.
In the event that any affected personal data has been disclosed to third
parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible
or would require disproportionate effort to do so).
The Company processes personal data using automated means.
Where data subjects have given their consent to the Company to process
their personal data in such a manner or the processing is otherwise required for the performance of a contract
between the Company and the data subject, data subjects have the legal right under the Regulation to receive a copy
of their personal data and to use it for other purposes (namely transmitting it to other Data Controllers, e.g.
To facilitate the right of data portability, the Company shall make
available all applicable personal data to data subjects in the following format:
JPG/JPEG/PNG as screenshots
Where technically feasible, if requested by a data subject, personal data shall be sent
directly to another Data Controller.
All requests for copies of personal data shall be complied with within one month of the data
subject’s request (this can be extended by up to two months in the case of complex requests in the case of complex
or numerous requests, and in such cases the data subject shall be informed of the need for the extension).
Objections to Personal Data Processing
Data subjects have the right to object to the Company processing their
personal data based on legitimate interests (including profiling), direct marketing (including profiling), and
processing for scientific and/or historical research and statistics purposes.
Where a data subject objects to the Company processing their personal
data based on its
legitimate interests, the Company shall cease such processing forthwith, unless it can be demonstrated
that the Company’s legitimate grounds for such processing override the data subject’s interests, rights and
freedoms; or the processing is necessary for the conduct of legal claims.
Where a data subject objects to the Company processing their personal
data for direct marketing purposes, the Company shall cease such processing forthwith.
Where a data subject objects to the Company processing their personal
data for scientific and/or historical research and statistics purposes, the data subject must, under the
Regulation, ‘demonstrate grounds relating to his or her particular situation’. The Company is not required to
comply if the research is necessary for the performance of a task carried out for reasons of public interest.
In the event that the Company uses personal data for the purposes of
automated decision-making and those decisions have a legal (or similarly significant effect) on data subjects, data
subjects have the right to challenge to such decisions under the Regulation, requesting human intervention,
expressing their own point of view, and obtaining an explanation of the decision from the Company.
The right described in Part 21.1 does not apply in the following
The decision is necessary for the entry into, or
performance of, a contract between the Company and the data subject;
The decision is authorised by law; or
The data subject has given their explicit
Where the Company uses personal data for profiling purposes, the following shall apply:
Clear information explaining the profiling will be provided, including its significance and
the likely consequences;
Appropriate mathematical or statistical procedures will be used;
Technical and organisational measures necessary to minimise the risk of errors and to enable
such errors to be easily corrected shall be implemented; and
All personal data processed for profiling purposes shall be secured in order to prevent
discriminatory effects arising out of profiling (see Parts 22 and 23 of this Policy for more details on data
Section D: Our Other Obligations
The Company’s data protection officer is Doyle Chambers, director,
The Company shall keep written internal records of all personal data
collection, holding, and processing, which shall incorporate the following information:
The name and details of the Company, its data
protection officer, and any applicable third party Data Controllers;
The purposes for which the Company processes
Details of the categories of personal data
collected, held, and processed by the Company; and the categories of data subject to which that personal data
Details (and categories) of any third parties
that will receive personal data from the
Details of any transfers of personal data to
non-EEA countries including all mechanisms and security safeguards;
Details of how long personal data will be
retained by the Company; and
Detailed descriptions of all technical and
organisational measures taken by the Company to ensure the security of personal data.
Privacy Impact Assessments
The Company shall carry out Privacy Impact Assessments when and as required under the Regulation. Privacy
Impact Assessments shall be overseen by the Company’s data protection officer and shall address the following
areas of importance:
The purpose(s) for which personal data is being processed and the processing operations to be
carried out on that data;
Details of the legitimate interests being pursued by the Company;
An assessment of the necessity and proportionality of the data processing with respect to the
purpose(s) for which it is being processed;
The Company shall ensure that the following measures are taken with respect to the collection, holding, and
processing of personal data:
All employees, agents, contractors, or other parties working on behalf of the Company shall
be made fully aware of both their individual responsibilities and the Company’s responsibilities under the
Regulation and under this Policy, and shall be provided with a copy of this Policy;
Only employees, agents, sub-contractors, or other parties working on behalf of the Company that
need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access
to personal data held by the Company;
All employees, agents, contractors, or other parties working on behalf of the Company handling
personal data will be appropriately trained to do so;
All employees, agents, contractors, or other parties working on behalf of the Company handling
personal data will be appropriately supervised;
Methods of collecting, holding and processing personal data shall be regularly evaluated and
The performance of those employees, agents, contractors, or other parties working on behalf of
the Company handling personal data shall be regularly evaluated and reviewed;
All employees, agents, contractors, or other parties working on behalf of the Company handling
personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by
All agents, contractors, or other parties working on behalf of the Company handling personal
data must ensure that any and all of their employees who are involved in the processing of personal data are held
to the same conditions as those relevant employees of the Company arising out of this Policy and the
Where any agent, contractor or other party working on behalf of the Company handling personal
data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against
any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
Transferring Personal Data to a Country Outside the EEA
The Company may from time to time transfer (‘transfer’ includes making
available remotely) personal data to countries outside of the EEA.
The transfer of personal data to a country outside of the EEA shall take
place only if one or more of the following applies:
The transfer is to a country, territory, or one
or more specific sectors in that country (or an international organisation), that the European Commission has
determined ensures an adequate level of protection for personal data;
The transfer is to a country (or international
organisation) which provides appropriate safeguards in the form of a legally binding agreement between public
authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European
Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information
Commissioner’s Office); certification under an approved certification mechanism (as provided for in the
Regulation); contractual clauses agreed and authorised by the competent supervisory authority; or provisions
inserted into administrative arrangements between public authorities or bodies authorised by the competent
The transfer is made with the informed consent
of the relevant data subject(s);
The transfer is necessary for the performance of
a contract between the data subject and the
Company (or for pre-contractual steps taken at the request of the data subject);
The transfer is necessary for important public
The transfer is necessary for the conduct of
The transfer is necessary to protect the vital
interests of the data subject or other individuals where the data subject is physically or legally unable to give
their consent; or
The transfer is made from a register that, under
UK or EU law, is intended to provide information to the public and which is open for access by the public in
general or otherwise to those who are able to show a legitimate interest in accessing the register.
Data Breach Notification
All personal data breaches must be reported immediately to the Company’s
data protection officer.
If a personal data breach occurs and that breach is likely to result in
a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination,
reputational damage, or other significant social or economic damage), the data protection officer must ensure that
the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours
after having become aware of it.
In the event that a personal data breach is likely to result in a high
risk (that is, a higher risk than that described under Part 27.2) to the rights and freedoms of data subjects, the
data protection officer must ensure that all affected data subjects are informed of the breach directly and without
Data breach notifications shall include the following information:
The categories and approximate number of data
The categories and approximate number of
personal data records concerned;
The name and contact details of the Company’s
data protection officer (or other contact point where more information can be obtained);
The likely consequences of the breach;
Details of the measures taken, or proposed to be
taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse
Implementation of Policy
This Policy shall be deemed effective as of May 21st, 2018. No part of this Policy shall have retroactive effect
and shall thus apply only to matters occurring on or after this date.
Schedule 1: Our Use Of Personal Data And Our Purpose
The following personal data may be collected, held, and processed by the Company:
Name, for personalization in marketing emails, online chat, and forums;
Email, so we know where to send our newsletters, offers, digital products, and delivery of any
products and services you purchase from us;
Country, so that we can send specific marketing materials based on your country, and send our
newsletters based on your time zone;
Schedule 2: Our Specific Data Protection Measures
These are the measures we take when working with personal data:
All emails containing personal data must be encrypted using XTS-AES-128 encryption with a
Where any personal data is to be erased or otherwise disposed of for any reason (including where
copies have been made and are no longer needed), it should be securely deleted and disposed of.
Hardcopies should be shredded, and electronic copies should be deleted securely.
Personal data may be transmitted over secure networks only; transmission over unsecured networks
is not permitted in any circumstances;
Personal data may not be transmitted over a wireless network if there is a wired alternative
that is reasonably practicable;
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 should be deleted. All temporary files associated
therewith should also be deleted;
Where Personal data is to be sent by facsimile transmission the recipient should be informed in
advance of the transmission and should be waiting by the fax machine to receive the data;
Where Personal data is to be transferred in hardcopy form it should be passed directly to the
recipient via postal service;
No personal data may be shared informally and if an employee, agent, sub-contractor, or other
party working on behalf of the Company requires access to any personal data that they do not already have access
to, such access should be formally requested from Doyle Chambers, Director, email@example.com;
All hardcopies of personal data, along with any electronic copies stored on physical, removable
media should be stored securely in a locked box, drawer, cabinet or similar;
No personal data may be transferred to any employees, agents, contractors, or other parties,
whether such parties are working on behalf of the Company or not, without the authorisation of Doyle Chambers,
Personal data must be handled with care at all times and should not be left unattended or on
view to unauthorised employees, agents, sub-contractors or other parties at any time;
If personal data is being viewed on a computer screen and the computer in question is to be left
unattended for any period of time, the user must lock the computer and screen before leaving it;
No personal data should be stored on any mobile device (including, but not limited to, laptops,
tablets and smartphones), whether such device belongs to the Company or otherwise without the formal written
approval of Doyle Chambers, Director, firstname.lastname@example.org and, in the event of such approval,
strictly in accordance with all instructions and limitations described at the time the approval is given, and for
no longer than is absolutely necessary]
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 the Company where the party in question has agreed to comply fully with the letter and spirit of this
Policy and of the Regulation (which may include demonstrating to the Company that all suitable technical and
organisational measures have been taken);
All personal data stored electronically should be backed up weekly with backups stored offsite.
All backups transferred using 256-bit SSL/TLS encryption and files stored encrypted using 128-bit AES keys.
All electronic copies of personal data should be stored securely using passwords and 128-bit AES
keys data encryption;
All passwords used to protect personal data should be changed regularly and should not use words
or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of
uppercase and lowercase letters, numbers, and symbols;
Under no circumstances should any passwords be written down or shared between any employees,
agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or
If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to
Where personal data held by the Company is used for marketing purposes, it shall be the
responsibility of Doyle Chambers, director, email@example.com, to ensure that no data subjects have
added their details to any marketing preference databases including, but not limited to, the Telephone Preference
Service, the Mail Preference Service, the Email Preference Service, and the Fax
Preference Service. Such details should be checked at least every six months.
All terms of this document equally applies to
all other website domains registered in the name of Doyle Chambers.
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