Greengage GDPR Commitment
Greengage is committed to the principles inherent in the GDPR and particularly to the concepts of privacy by design, the right to be forgotten, consent and a risk-based approach. In addition, we aim to ensure:

• transparency with regard to the use of data
• that any processing is lawful, fair, transparent and necessary for a specific purpose
• that data is accurate, kept up to date and removed when no longer necessary
• that data is kept safely and securely.

Staffing
Our Data Protection Officer (DPO) works to promote awareness of GDPR throughout Greengage. Our DPO oversees the Group’s commitment to best practice and informs and advises the Group and monitors compliance.

Right to be forgotten
We recognise the right to erasure, also known as the right to be forgotten, laid down in the GDPR. Individuals should contact gdpr@greengage.co with requests for the deletion or removal of personal data. These will be acted on provided there is no compelling reason for continued processing and that the exemptions set out in the GDPR do not apply. These exemptions include where the personal data is processed for the exercise or defence of legal claims and to comply with a legal obligation for the performance of a public interest task or exercise of official authority.

Subject Access Requests
We recognise that individuals have the right to access their personal data and supplementary information and will comply with the one month timeframe for responses set down in the GDPR. As a general rule, a copy of the requested information will be provided free of charge although we reserve the right to charge a “reasonable fee” when a request is manifestly unfounded or excessive, particularly if it is repetitive. If this proves necessary, the data subject will be informed of their right to contest our decision with the supervisory authority (the Information Commissioner’s Office (ICO)). Any fee will be notified in advance and will be based on the administrative cost of providing the information.

Privacy
We will implement data protection “by design and by default”, as required by the GDPR. Safeguards will be built into products and services from the earliest stage of development and privacy-friendly default settings will be the norm. The Privacy Policy, which is on our website and which is provided to anyone from whom we collect data, explains our lawful basis for processing the data and gives the data retention periods. It makes clear that individuals have a right to complain to the ICO.

The privacy information notices can be accessed here.

Data Transfers Outside of the UK & EU
Where appropriate and necessary we have put recognised procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of any personal data that is transferred to countries outside of the UK & EU. Diligence checks are carried out to ensure that such countries have the necessary safeguards in place, provide enforceable data subject rights and offer effective legal remedies for data subjects where applicable.

Data Loss
If a data breach occurs that is likely to result in a risk to the rights and freedoms of individuals, the people affected will be informed as soon as possible and the ICO will be notified within 72 hours.

GDPR Contact
Any questions related to GDPR or to issues concerning data protection generally should initially be addressed to gdpr@greengage.co