1. Introduction
1.1 Background to the UK General Data Protection Regulation (‘UK GDPR’)
UK organisations that process personal data must now comply with the DPA (Data
Protection Act) 2018 and UK GDPR (General Data Protection Regulation) if they process
only domestic personal data. The purpose of the legislation is to protect the “rights and
freedoms” of natural persons (i.e. Living individuals) and to ensure that personal data is not
processed without their knowledge, and, wherever possible, that it is processed with their
consent.
1.2 Definitions used by the organisation (drawn from the UK GDPR)
Material scope (Article 2) – the UK GDPR applies to the processing of personal data wholly
or partly by automated means (i.e. by computer) and to the processing other than by
automated means of personal data (i.e. paper records) that form part of a filing system or are
intended to form part of a filing system.
Territorial scope (Article 3) – the UK GDPR will apply to all controllers that are established in
the UK (United Kingdom) who process the personal data of data subjects, in the context of
that establishment. It will also apply to controllers outside of the UK that process personal
data in order to offer goods and services, or monitor the behaviour of data subjects who are
resident in the UK.
1.3 Article 4 definitions
Establishment – the main establishment of the controller in the UK will be the place in which
the controller makes the main decisions as to the purpose and means of its data processing
activities. The main establishment of a processor in the UK will be its administrative centre. If
a controller is based outside the UK, it will have to appoint a representative in the jurisdiction
in which the controller operates to act on behalf of the controller and deal with supervisory
authorities.
Personal data – any information relating to an identified or identifiable natural person ('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.
Special categories of personal data – personal data revealing racial or ethnic origin, political
opinions, religious or philosophical beliefs, or trade-union membership, and the processing
of genetic data, biometric data for the purpose of uniquely identifying a natural person, data
concerning health or data concerning a natural person's sex life or sexual orientation.
Data controller – the 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; where the purposes and means of such processing are determined by UK
law, the controller or the specific criteria for its nomination may be provided for by UK law.
Data subject – any living individual who is the subject of personal data held by an
organisation.Processing – any operation or set of operations which is performed on personal data or on
sets of personal data, whether or not by automated means, such as 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.
Profiling – is any form of automated processing of personal data intended to evaluate certain
personal aspects relating to a natural person, or to analyse or predict that person’s
performance at work, economic situation, location, health, personal preferences, reliability, or
behaviour. This definition is linked to the right of the data subject to object to profiling and a
right to be informed about the existence of profiling, of measures based on profiling and the
envisaged effects of profiling on the individual.
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. There is an obligation on the controller to report
personal data breaches to the supervisory authority and where the breach is likely to
adversely affect the personal data or privacy of the data subject.
Data subject consent - means 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.
Child – the UK GDPR defines a child as anyone under the age of 16 years old. The
processing of personal data of a child is only lawful if parental or custodian consent has
been obtained. The controller shall make reasonable efforts to verify in such cases that
consent is given or authorised by the holder of parental responsibility over the child.
Third party – a natural or legal person, public authority, agency or body other than the data
subject, controller, processor and persons who, under the direct authority of the controller or
processor, are authorised to process personal data.
Filing system – any structured set of personal data which are accessible according to
specific criteria, whether centralised, decentralised or dispersed on a functional or
geographical basis.
2. Policy statement
2.1 The Board of Directors and management of ICB General Building and Civil Engineering
Ltd., located at 212A Green Street Enfield EN3 7NB are committed to compliance with all
relevant EU and Member State laws in respect of personal data, and the protection of the
“rights and freedoms” of individuals whose information ICB General Building and Civil
Engineering Ltd. collects and processes in accordance with the UK General Data Protection
Regulation (UK GDPR).
2.2 Compliance with the UK GDPR is described by this policy and other relevant policies
such as the Information Security Policy, along with connected processes and procedures.
2.3 The UK GDPR and this policy apply to all of ICB General Building and Civil Engineering
Ltd.’s personal data processing functions, including those performed on customers’, clients’,
employees’, suppliers’ and partners’ personal data, and any other personal data the
organisation processes from any source.
2.4 ICB General Building and Civil Engineering Ltd. has established objectives for data
protection and privacy, which are documented2.5 The Finance Manager is responsible for
reviewing the register of data processingannually in the light of any changes to ICB General
Building and Civil Engineering Ltd.’s activities (as determined by changes to the data inventory
register and the management review) and to any additional requirements identified by means
of data protection impact assessments. This register needs to be available on the
supervisory authority’s request.
2.6 This policy applies to all Employees/Staff and interested parties of ICB General Building
and Civil Engineering Ltd. such as outsourced suppliers. Any breach of the UK GDPR or this
PIMS (personal information management system) will be dealt with under ICB General
Building and Civil Engineering Ltd.’s disciplinary policy and may also be a criminal offence,
in which case the matter will be reported as soon as possible to the appropriate authorities.
2.7 Partners and any third parties working with or for ICB General Building and Civil
Engineering Ltd., and who have or may have access to personal data, will be expected to
have read, understood and to comply with this policy. No third party may access personal
data held by ICB General Building and Civil Engineering Ltd. without having first entered into
a data confidentiality agreement, which imposes on the third party obligations no less
onerous than those to which ICB General Building and Civil Engineering Ltd. is committed,
and which gives ICB General Building and Civil Engineering Ltd. the right to audit
compliance with the agreement.
3. Responsibilities and roles under the UK General Data Protection Regulation
3.1 ICB General Building and Civil Engineering Ltd. is a data processor of client data and a
data controller of employee data under the GDPR.
3.2 Top Management and all those in managerial or supervisory roles throughout ICB
General Building and Civil Engineering Ltd. are responsible for developing and encouraging
good information handling practices
within ICB General Building and Civil Engineering Ltd.; responsibilities are set out in
individual job descriptions.
3.3 The is a role specified in the UK GDPR and is a member of the senior management
team. They are accountable to Board of Directors of ICB General Building and Civil
Engineering Ltd. for the management of personal data within ICB General Building and Civil
Engineering Ltd. and for ensuring that compliance with data protection legislation and good
practice can be demonstrated. This accountability includes:
3.3.1 development and implementation of the UK GDPR as required by this policy; and
3.3.2 security and risk management in relation to compliance with the policy.
3.4 The GDPR Owner, whom the Board of Directors considers to be suitably qualified and
experienced, has been appointed to take responsibility for ICB General Building and Civil
Engineering Ltd.’s compliance with this policy on a day-to-day basis and, in particular, has
direct responsibility for ensuring that ICB General Building and Civil Engineering Ltd.
complies with the UK GDPR, as do employees in respect of data processing that takes place
within their area of responsibility.
3.5 The GDPR Owner have specific responsibilities in respect of procedures such as the
Subject Access Request Procedure and are the first point of call for Employees/Staff seeking
clarification on any aspect of data protection compliance.
3.6 Compliance with data protection legislation is the responsibility of all Employees/Staff of
ICB General Building and Civil Engineering Ltd. who process personal data.3.7 ICB General Building
and Civil Engineering Ltd.’s Training Policy sets out specific training and awareness requirements
in relation to specific roles and Employees/Staff of ICB General Building and Civil Engineering Ltd. generally.
3.8 Employees/Staff of ICB General Building and Civil Engineering Ltd. are responsible for
ensuring that any personal data about them and supplied by them to ICB General Building
and Civil Engineering Ltd. is accurate and up-to- date.
4. Data protection principles
All processing of personal data must be conducted in accordance with the data protection
principles as set out in Article 5 of the UK GDPR. ICB General Building and Civil Engineering
Ltd.’s policies and procedures are designed to ensure compliance with the principles.
4.1 Personal data must be processed lawfully, fairly and transparently
Lawful – identify a lawful basis before you can process personal data. These are often
referred to as the
“conditions for processing”, for example consent.
Fairly – in order for processing to be fair, the data controller has to make certain information
available to the data subjects as practicable. This applies whether the personal data was
obtained directly from the data subjects or from other sources.
The UK GDPR has increased requirements about what information should be available to
data subjects, which is covered in the ‘Transparency’ requirement.
Transparently – the UK GDPR includes rules on giving privacy information to data subjects
in Articles 12, 13 and 14.
These are detailed and specific, placing an emphasis on making privacy notices
understandable and accessible.
Information must be communicated to the data subject in an intelligible form using clear and
plain language. ICB General Building and Civil Engineering Ltd. has a documented
employee Privacy Notice and Procedure. The specific information that must be provided to
the data subject must, as a minimum, include:
4.1.1 the identity and the contact details of the controller and, if any, of the controller's
representative;
4.1.2 the purposes of the processing for which the personal data are intended as well as the
legal basis for the processing;
4.1.3 the period for which the personal data will be stored;
4.1.4 the existence of the rights to request access, rectification, erasure or to object to the
processing, and the conditions (or lack of) relating to exercising these rights, such as
whether the lawfulness of previous processing will be affected;
4.1.5 the categories of personal data concerned;
4.1.6 the recipients or categories of recipients of the personal data, where applicable;
4.1.7 where applicable, that the controller intends to transfer personal data to a recipient in a
third country and the level of protection afforded to the data;
4.1.8 any further information necessary to guarantee fair processing.4.2 Personal data can only be
collected for specific, explicit and legitimate purposes. Data obtained for specified purposes must
not be used for a purpose that differs from those formally notified to the supervisory authority as part of ICB
General Building and Civil Engineering Ltd.’s UK GDPR register of processing. The Privacy Procedure sets out the
relevant procedures.
4.3 Personal data must be adequate, relevant and limited to what is necessary for
processing
4.3.1 The GDPR Owner is responsible for ensuring that ICB General Building and Civil
Engineering Ltd. Does not collect information that is not strictly necessary for the purpose for
which it is obtained
4.3.2 All data collection forms (electronic or paper-based), including data collection
requirements in new information systems, must be include a fair processing statement or link
to privacy statement and approved by the GDPR Owner.
4.3.3 The GDPR Owner will ensure that, at least annually, all data collection methods are
reviewed to ensure that collected data continues to be adequate, relevant and not excessive.
4.4 Personal data must be accurate and kept up to date with every effort to erase or rectify
without delay
4.4.1 Data that is stored by the data controller must be reviewed and updated as necessary.
No data should be kept unless it is reasonable to assume that it is accurate.
4.4.2 The Directors are responsible for ensuring that all staff are trained in the importance of
collecting accurate data and maintaining it.
4.4.3 It is also the responsibility of the data subject to ensure that data held by ICB General
Building and Civil Engineering Ltd. is accurate and up to date. Completion of a registration or
application form by a data subject will include a statement that the data contained therein is
accurate at the date of submission.
4.4.4 Employees/Staff should be required to notify ICB General Building and Civil
Engineering Ltd. of any changes in circumstance to enable personal records to be updated
accordingly. It is the responsibility of ICB General Building and Civil Engineering Ltd. to
ensure that any notification regarding change of circumstances is recorded and acted upon.
4.4.5 The Finance Manager is responsible for ensuring that appropriate procedures and
policies are in place to keep personal data accurate and up to date, taking into account the
volume of data collected, the speed with which it might change and any other relevant
factors.
4.4.6 On at least an annual basis, the GDPR Owner will review the retention dates of all the
personal data processed by ICB General Building and Civil Engineering Ltd., by reference to
the data inventory, and will identify any data that is no longer required in the context of the
registered purpose. This data will be securely deleted/destroyed in line with the Secure
Disposal of Storage Media Procedure
4.4.7 The GDPR Owner is responsible for responding to requests for rectification from data
subjects within one month (Subject Access Request Procedure). This can be extended to a
further two months for complex requests. If ICB General Building and Civil Engineering Ltd.
decides not to comply with the request, the GDPR Owner must respond to the data subject
to explain its reasoning and inform them of their right to complain to the supervisory authority
and seek judicial remedy.
4.4.8 The GDPR Owner is responsible for making appropriate arrangements that, where
third-party organisations may have been passed inaccurate or out-of-date personal data, to
inform them that the information is inaccurate and/or out of date and is not to be used to
inform decisions about the individuals concerned; and for passing any correction to the
personal data to the third party where this is required.
4.5 Personal data must be kept in a form such that the data subject can be identified only as
long as is necessary for processing.
4.5.1 Where personal data is retained beyond the processing date, it will be encrypted or
pseudonymized in order to protect the identity of the data subject in the event of a data
breach.
4.5.2 Personal data will be retained in line with the Retention of Records Procedure and,
once its retention
date is passed, it must be securely destroyed as set out in this procedure.
4.5.3 The GDPR Owner must specifically approve any data retention that exceeds the
retention periods defined in Retention of Records Procedure and must ensure that the
justification is clearly identified and in line with the requirements of the data protection
legislation. This approval must be written.
4.6 Personal data must be processed in a manner that ensures the appropriate security
The GDPR Owner will carry out a risk assessment taking into account all the circumstances
of ICB General Building and Civil Engineering Ltd.’s controlling or processing operations.
In determining appropriateness, the GDPR Owner should also consider the extent of
possible damage or loss that might be caused to individuals (e.g. staff or customers) if a
security breach occurs, the effect of any security breach on ICB General Building and Civil
Engineering Ltd. itself, and any likely reputational damage including the possible loss of
customer trust.
When assessing appropriate technical measures, the GDPR Owner will consider the
following:
• Password protection
• Automatic locking of idle terminals;
• Removal of access rights for USB and other memory media
• Virus checking software and firewalls
• Role-based access rights including those assigned to temporary staff
• Encryption of devices that leave the organisations premises such as laptops
• Security of local and wide area networks
• Privacy enhancing technologies such as pseudonymisation and anonymisation;
• Identifying appropriate international security standards relevant to ICB General Building
and Civil Engineering Ltd.
When assessing appropriate organisational measures the GDPR Owner will consider the
following:
• The appropriate training levels throughout ICB General Building and Civil Engineering Ltd.;
• Measures that consider the reliability of employees (such as references etc.);
• The inclusion of data protection in employment contracts;
• Identification of disciplinary action measures for data breaches;
• Monitoring of staff for compliance with relevant security standards;
• Physical access controls to electronic and paper based records;
• Adoption of a clear desk policy;
• Storing of paper based data in lockable fire-proof cabinets;
• Restricting the use of portable electronic devices outside of the workplace;
• Restricting the use of employee’s own personal devices being used in the workplace;
• Adopting clear rules about passwords;
• Making regular backups of personal data and storing the media off-site;
• The imposition of contractual obligations on the importing organisations to take appropriate
security measures when transferring data outside the EEA.
These controls have been selected on the basis of identified risks to personal data, and the
potential for damage or distress to individuals whose data is being processed.
4.7 The controller must be able to demonstrate compliance with the UK GDPR’s other
principles (accountability)
The UK GDPR includes provisions that promote accountability and governance. These
complement the UK GDPR’s transparency requirements. The accountability principle in
Article 5(2) requires you to demonstrate that you comply with the principles and states
explicitly that this is your responsibility.
The ICB General Building and Civil Engineering Ltd. will demonstrate compliance with the
data protection principles by implementing data protection policies, adhering to codes of
conduct, implementing technical and organisational measures, as well as adopting
techniques such as data protection by design, DPIAs, breach notification procedures and
incident response plans.
4.8 Data subjects have the following rights regarding data processing, and the data that is
recorded about them:
4.8.1 To make subject access requests regarding the nature of information held and to whom
it has been disclosed.
4.8.2 To prevent processing likely to cause damage or distress.4.8.3 To prevent processing for
purposes of direct marketing.
4.8.4 To be informed about the mechanics of automated decision-taking process that will
significantly affect them.
4.8.5 To not have significant decisions that will affect them taken solely by automated
process.
4.8.6 To sue for compensation if they suffer damage by any contravention of the UK GDPR.
4.8.7
4.8.8 To request the supervisory authority to assess whether any provision of the UK GDPR
has been contravened.
4.8.9 To have personal data provided to them in a structured, commonly used and machine-
readable
format, and the right to have that data transmitted to another controller.
4.8.10 To object to any automated profiling that is occurring without consent.
4.9 ICB General Building and Civil Engineering Ltd. ensures that data subjects may exercise
these rights:
4.9.1 Data subjects may make data access requests as described in Subject Access
Request Procedure this procedure also describes how ICB General Building and Civil
Engineering Ltd. will ensure that its response to the data access request complies with the
requirements of the UK GDPR.
4.9.2 Data subjects have the right to complain to ICB General Building and Civil Engineering
Ltd. related to the processing of their personal data, the handling of a request from a data
subject and appeals from a data subject on how complaints have been handled in line with
the Complaints Procedure
5. Consent
5.1 ICB General Building and Civil Engineering Ltd. understands ‘consent’ to mean that it
has been explicitly and freely given, and a specific, informed and unambiguous indication of
the data subject’s wishes that, by statement or by a clear affirmative action, signifies
agreement to the processing of personal data relating to him or her. The data subject can
withdraw their consent at any time.
5.2 ICB General Building and Civil Engineering Ltd. understands ‘consent’ to mean that the
data subject has been fully informed of the intended processing and has signified their
agreement, while in a fit state of mind to do so and without pressure being exerted upon
them. Consent obtained under duress or on the basis of misleading information will not be a
valid basis for processing.
5.3 There must be some active communication between the parties to demonstrate active
consent. Consent cannot be inferred from non-response to a communication. The Controller
must be able to demonstrate that consent was obtained for the processing operation.
5.4 For sensitive data, explicit written consent of data subjects must be obtained unless an
alternative legitimate basis for processing exists.5.5 In most instances, consent to process
personal and sensitive data is obtained routinely by ICB General Building and Civil Engineering Ltd.
using standard consent documents e.g. when a new client signs a contract, or during induction for
participants on programmes.
5.6 Where ICB General Building and Civil Engineering Ltd. provides online services to
children, parental or custodial authorisation must be obtained. This requirement applies to
children under the age of 16 (unless the Member State has made provision for a lower age
limit, which may be no lower than13).
6. Security of data
6.1 All Employees/Staff are responsible for ensuring that any personal data that ICB General
Building and Civil Engineering Ltd. holds and for which they are responsible, is kept securely
and is not under any conditions disclosed to any third party unless that third party has been
specifically authorised by ICB General Buildingand Civil Engineering Ltd. to receive that
information and has entered into a confidentiality agreement.
6.2 All personal data should be accessible only to those who need to use it, and access may
only be granted inline
with the Access Control Policy . All personal data should be treated with the highest security
and must be kept: in a lockable room with controlled access; and/or
in a locked drawer or filing cabinet; and/or
if computerised, password protected in line with corporate requirements in the Access
Control Policy and/or stored on (removable) computer media which are encrypted in line with
Secure Disposal of Storage Media
6.3 Care must be taken to ensure that PC screens and terminals are not visible except to
authorised Employees/Staff of ICB General Building and Civil Engineering Ltd.. All
Employees/Staff are required to enter into an Acceptable Use Agreement before they are
given access to organisational information of any sort, which details rules on screen time-
outs.
6.4 Manual records may not be left where they can be accessed by unauthorised personnel
and may not be removed from business premises without explicit [written] authorisation. As
soon as manual records are no
longer required for day-to-day client support, they must be removed from secure archiving in
line with company procedures.
6.5 Personal data may only be deleted or disposed of in line with the Retention of Records
Procedure (Manual records that have reached their retention date are to be shredded and
disposed of as ‘confidential waste’. Hard drives of redundant PCs are to be removed and
immediately destroyed as required by before disposal.
6.6 Processing of personal data ‘off-site’ presents a potentially greater risk of loss, theft or
damage to personal data. Staff must be specifically authorised to process data off-site.
7. Disclosure of data
7.1 ICB General Building and Civil Engineering Ltd. must ensure that personal data is not
disclosed to unauthorised third parties which includes family members, friends, government
bodies, and in certain circumstances, the Police. All Employees/Staff should exercise
caution when asked to disclose personal data held on another individual to a third party.
It isimportant to bear in mind whether or not disclosure of the information is relevant to, and
necessary for, the conduct of ICB General Building and Civil Engineering Ltd.’s business.
7.2 All requests to provide data for one of these reasons must be supported by appropriate
paperwork and all such disclosures must be specifically authorised by the GDPR Owner.
8. Retention and disposal of data
8.1 ICB General Building and Civil Engineering Ltd. shall not keep personal data in a form
that permits identification of data subjects for longer a period than is necessary, in relation to
the purpose(s) for which the data was originally collected.
8.2 ICB General Building and Civil Engineering Ltd. may store data for longer periods if the
personal data will be processed solely for archiving purposes in the public interest, scientific
or historical research purposes or statistical purposes, subject to the implementation of
appropriate technical and organisational measures to safeguard the rights and freedoms of
the data subject.
8.3 The retention period for each category of personal data will be set out in the Retention of
Records Procedure along with the criteria used to determine this period including any
statutory obligations ICB General Building and Civil Engineering Ltd. has to retain the data.
8.4 ICB General Building and Civil Engineering Ltd.’s data retention and data disposal
procedures will apply in all cases.
8.5 Personal data must be disposed of securely in accordance with the sixth principle of the
UK GDPR –processed in an appropriate manner to maintain security, thereby protecting the
“rights and freedoms” of data subjects. Any disposal of data will be done in accordance with
the secure disposal procedure
9. Data transfers
9.1 All exports of data from within the European Economic Area (EEA) to non-European
Economic Area countries (referred to in the UK GDPR as ‘third countries’) are unlawful
unless there is an appropriate “level of protection for the fundamental rights of the data
subjects”.
The transfer of personal data outside of the EEA is prohibited unless one or more of the
specified safeguards, or
exceptions, apply:
9.1.1 An adequacy decision
The UK will assess third countries, a territory and/or specific sectors within third countries to
assess whether there is an appropriate level of protection for the rights and freedoms of
natural persons. In these instances, no authorisation is required.
Countries that are members of the European Economic Area (EEA) but not of the EU are
accepted as having met the conditions for an adequacy decision.
A list of countries that currently satisfy the adequacy requirements of the Commission are
published in the Official Journal of the European Union. http://ec.europa.eu/justice/data-
protection/international-transfers/adequacy/index_en.htm
9.1.2 Privacy ShieldIf ICB General Building and Civil Engineering Ltd. wishes to transfer personal data from the
EU to an organisation in the United States it should check that the organisation is signed up
with the Privacy Shield framework at the U.S. Department of Commerce. The obligation
applying to companies under the Privacy Shield are contained in the “Privacy Principles”.
The US DOC is responsible for managing and administering the Privacy Shield and ensuring
that companies live up to their commitments. In order to be able to certify, companies must
have a privacy policy in line with the Privacy Principles
e.g. use, store and further transfer the personal data according to a strong set of data
protection rules and safeguards. The protection given to the personal data applies
regardless of whether the personal data is related to an EU resident or not. Organisations
must renew their “membership” to the Privacy Shield on an annual basis. If they do not, they
can no longer receive and use personal data from the EU under that framework.
Assessment of adequacy by the data controller
In making an assessment of adequacy, the UK based exporting controller should take
account of the following factors:
• the nature of the information being transferred;
• the country or territory of the origin, and final destination, of the information;
• how the information will be used and for how long;
• the laws and practices of the country of the transferee, including relevant codes of practice
and international obligations; and
• the security measures that are to be taken as regards the data in the overseas location.
9.1.3 Binding corporate rules
ICB General Building and Civil Engineering Ltd. may adopt approved binding corporate rules
for the transfer of data outside the EU. This requires submission to the relevant supervisory
authority for approval of the rules that ICB General Building and Civil Engineering Ltd. is
seeking to rely upon.
9.1.4 Model contract clauses
ICB General Building and Civil Engineering Ltd. may adopt approved model contract clauses
for the transfer of data outside of the EEA. If ICB General Building and Civil Engineering Ltd.
adopt the model contract clauses approved by the relevant supervisory authority there is an
automatic recognition of adequacy.
9.1.5 Exceptions
In the absence of an adequacy decision, Privacy Shield membership, binding corporate rules
and/or model contract clauses, a transfer of personal data to a third country or international
organisation shall only take place on one of the following conditions:
• the data subject has explicitly consented to the proposed transfer, after having been
informed of the possible risks of such transfers for the data subject due to the absence of an
adequacy decision and appropriate safeguards;
• the transfer is necessary for the performance of a contract between the data subject and
the controller or the implementation of pre-contractual measures taken at the data subject's
request;• the transfer is necessary for the conclusion or performance of a contract concluded in the
interest of the data subject between the controller and another natural or legal person;
• the transfer is necessary for important reasons of public interest;
• the transfer is necessary for the establishment, exercise or defence of legal claims; and/or
• the transfer is necessary in order to protect the vital interests of the data subject or of other
persons, where the data subject is physically or legally incapable of giving consent.
10. Information asset register/data inventory
10.1 ICB General Building and Civil Engineering Ltd. has established a data inventory and
data flow process as part of its approach to address risks and opportunities throughout its
UK GDPR compliance project. ICB General Building and Civil Engineering Ltd.’s data
inventory and data flow determines:
• business processes that use personal data;
• source of personal data;
▪ volume of data subjects;
▪ description of each item of personal data;
▪ processing activity;
▪ maintains the inventory of data categories of personal data processed;
▪ documents the purpose(s) for which each category of personal data is used;
▪ recipients, and potential recipients, of the personal data;
▪ the role of the ICB General Building and Civil Engineering Ltd. throughout the data flow;
▪ key systems and repositories;
▪ any data transfers; and
▪ all retention and disposal requirements.
10.2 ICB General Building and Civil Engineering Ltd. is aware of any risks associated with
the processing of particular types of personal data.
10.2.1 ICB General Building and Civil Engineering Ltd. assesses the level of risk to
individuals associated with the processing of their personal data. Data protection impact
assessments (DPIAs) are carried out in relation to the processing of personal data by ICB
General Building and Civil Engineering Ltd., and in relation to processing undertaken by
other organisations on behalf of ICB General Building and Civil Engineering Ltd..
10.2.2 ICB General Building and Civil Engineering Ltd. shall manage any risks identified by
the risk assessment in order to reduce the likelihood of a non-conformance with this policy.
10.2.3 Where a type of processing, in particular using new technologies and taking into
account the nature, scope, context and purposes of the processing is likely to result in a high
risk to the rights and freedoms of natural persons, ICB General Building and Civil
Engineering Ltd. shall, prior to the processing, carry out a DPIA of the impact of the
envisaged processing operationson the protection of personal data. A single DPIA may
address a set of similar processing operations that present similar high risks.
10.2.4 Where, as a result of a DPIA it is clear that ICB General Building and Civil
Engineering Ltd. is about to commence processing of personal data that could cause
damage and/or distress to the data subjects, the decision as to whether or not ICB General
Building and Civil Engineering Ltd. may proceed must be escalated for review to the GDPR
Owner.
10.2.5 The GDPR Owner shall, if there are significant concerns, either as to the potential
damage or distress, or the quantity of data concerned, escalate the matter to the supervisory
authority.
10.2.6 Appropriate controls will be selected from Annex A of ISO 27001 and other 27000
series of Standards and applied to reduce the level of risk associated with processing
individual data to an acceptable level, by reference to ICB General Building and Civil
Engineering Ltd.’s documented risk acceptance criteria and the requirements of the UK
GDPR.
Document Owner and Approval
The GDPR Owner is the owner of this document and is responsible for ensuring that this
policy document is reviewed in line with the review requirements stated above.
A current version of this document is available to all members of staff on the server.
This policy was approved by the Board of Directors on 07/12/2020 and is issued on a
version-controlled basis under the signature of the Directors.
Amanda Janes
Managing Director
ICB General Building and Civil Engineering Ltd
Company Registered Address:
212a Green Street Enfield EN37NB
Company Registration No.: 08338857
