DATA PROTECTION POLICY

CONTENTS
1 PURPOSE........................................................................................................................................................... 2
2 SCOPE............................................................................................................................................................... 2
3 POLICY STATEMENT........................................................................................................................................ 2
3.1. Governance................................................................................................................................................. 2
3.2. Data Protection Principles........................................................................................................................... 2
3.3. Data collection............................................................................................................................................. 2
3.4. Data Use..................................................................................................................................................... 2
3.5. Data Retention............................................................................................................................................. 2
3.6. Data Protection............................................................................................................................................ 2
3.7. Data subject Requests................................................................................................................................ 2
3.8. Law Enforcement Requests & Disclosures.................................................................................................. 2
3.9. Data Protection Training.............................................................................................................................. 2
3.10. Data Transfers........................................................................................................................................ 2
3.11. Complaints handling................................................................................................................................ 2
3.12. Breach Reporting.................................................................................................................................... 2
4 ROLES AND RESPONSIBILITIES...................................................................................................................... 2
4.1 Implementation............................................................................................................................................ 2
4.2 Support, Advice and Communication.......................................................................................................... 2
5 REVIEW.............................................................................................................................................................. 2
6 RECORDS MANAGEMENT................................................................................................................................ 2
7 TERMS AND DEFINITIONS............................................................................................................................... 2
8 RELATED LEGISLATION AND DOCUMENTS................................................................................................... 2
9 FEEDBACK AND SUGGESTIONS..................................................................................................................... 2
10 APPROVAL AND REVIEW DETAILS................................................................................................................. 2
1 PURPOSE

This policy establishes an effective, accountable and transparent framework for ensuring compliance with the
requirements of the GDPR.

2 SCOPE

This policy applies to all Clark and Poole Limited employees and all third parties responsible for the
processing of persona data on behalf of Clark and Poole Limited services/entities.

3 POLICY STATEMENT

Clark and Poole Limited is committed to conducting its business in accordance with all applicable data
protection laws and regulations and in line with the highest standards of ethical conduct.

This policy sets forth the expected behaviours of Clark and Poole Limited employees and third parties in
relation to the collection, use, retention, transfer, disclosure and destruction of any personal data belonging
to a Clark and Poole Limited contact (i.e. the data subject).

Personal data is any information (including opinions and intentions) which relates to an identified or
identifiable natural person. Personal data is subject to certain legal safeguards and other regulations, which
impose restrictions on how organisations may process personal data. An organisation that handles personal
data and makes decisions about its use is known as a Data Controller. Clark and Poole Limited, as a Data
Controller, is responsible for ensuring compliance with the data protection requirements outlined in this
policy. Non-compliance may expose Clark and Poole Limited to complaints, regulatory action, fines and/or
reputational damage.

Clark and Poole Limited’s leadership is fully committed to ensuring continued and effective implementation of
this policy, and expects all Clark and Poole Limited employees and third parties to share in this commitment.
Any breach of this policy will be taken seriously and may result in disciplinary action or business sanction.

3.1. Governance
3.1.1.Data Protection Officer

To demonstrate our commitment to data protection, and to enhance the effectiveness of our compliance
efforts, Clark and Poole Limited has appointed a Data Protection Officer. The Data Protection Officer
operates with independence and is supported by suitability skilled individuals granted all necessary authority.
The Data Protection Officer reports to Clark and Poole Limited’s Directors. The Data Protection Officer’s
duties include:
 Informing and advising Clark and Poole Limited and its employees who carry out processing pursuant to
data protection regulations, national law or European Union based data protection provisions;
 Ensuring the alignment of this policy with data protection regulations, national law or European Union
based data protection provisions;
 Providing guidance with regards to carrying out Data Protection Impact Assessments (DPIAs);
 Acting as a point of contact for and cooperating with Data Protection Authorities (DPAs);
 Determining the need for notifications to one or more DPAs as a result of Clark and Poole Limited’s
current or intended personal data processing activities;
 Making and keeping current notifications to one or more DPAs as a result of Clark and Poole Limited’s
current or intended personal data processing activities;
 The establishment and operation of a system providing prompt and appropriate responses to data
subject requests;

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  Informing senior managers, officers, and directors of Clark and Poole Limited of any potential corporate,
civil and criminal penalties which may be levied against Clark and Poole Limited and/or its employees
for violation of applicable data protection laws.

Ensuring establishment of procedures and standard contractual provisions for obtaining compliance with this
Policy by any third party who:
 provides personal data to a Clark and Poole Limited service/entity
 receives personal data from a Clark and Poole Limited service/entity
 has access to personal data collected or processed by a Clark and Poole Limited

3.1.2.Data Protection by Design

To ensure that all data protection requirements are identified and addressed when designing new systems or
processes and/or when reviewing or expanding existing systems or processes, each of them must go
through an approval process before continuing. Each Clark and Poole Limited service/entity must ensure
that a Data Protection Impact Assessment (DPIA) is conducted, in cooperation with the Data Protection
Officer, for all new and/or revised systems or processes for which it has responsibility. The subsequent
findings of the DPIA must then be submitted to the Directors for review and approval. Where applicable, the
Information Technology (IT) department, as part of its IT system and application design review process, will
cooperate with the Data Protection Officer to assess the impact of any new technology uses on the security
of personal data.

3.1.3.Compliance Monitoring

To confirm that an adequate level of compliance that is being achieved by all Clark and Poole Limited
services/entities in relation to this policy, the Data Protection Officer will carry out an annual data protection
compliance audit for all such services/entities. Each audit will, as a minimum, assess:
 Compliance with policy in relation to the protection of personal data, including:
 The assignment of responsibilities.
 Raising awareness.
 Training of employees.
 The effectiveness of data protection related operational practices, including:
 Data subject rights.
 Personal data transfers.
 Personal data incident management.
 Personal data complaints handling.
 The level of understanding of data protection policies and privacy notices.
 The currency of data protection policies and privacy notices.
 The accuracy of personal data being stored.
 The conformity of data processor activities.
 The adequacy of procedures for redressing poor compliance and personal data breaches. The Data
Protection Officer, in cooperation with key business stakeholders from each Clark and Poole Limited
service/entity, will devise a plan with a schedule for correcting any identified deficiencies within a
defined and reasonable time frame. Any major deficiencies and good practice identified will be
reported to, monitored and shared by the Clark and Poole Limited Directors.

3.2. Data Protection Principles

Clark and Poole Limited has adopted the following principles to govern its collection, use, retention, transfer,
disclosure and destruction of personal data:

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 Principle 1: Lawfulness, Fairness and Transparency. Personal data shall be processed lawfully, fairly
and in a transparent manner in relation to the data subject. This means, Clark and Poole Limited must tell
the data subject what processing will occur (transparency), the processing must match the description given
to the data subject (fairness), and it must be for one of the purposes specified in the applicable data
protection regulation (lawfulness).

Principle 2: Purpose Limitation. Personal data shall be collected for specified, explicit and legitimate
purposes and not further processed in a manner that is incompatible with those purposes. This means Clark
and Poole Limited must specify exactly what the personal data collected will be used for and limit the
processing of that personal data to only what is necessary to meet the specified purpose.

Principle 3: Data Minimisation. Personal data shall be adequate, relevant and limited to what is necessary
in relation to the purposes for which they are processed. This means Clark and Poole Limited must not store
any personal data beyond what is strictly required.

Principle 4: Accuracy. Personal data shall be accurate and, kept up to date. This means Clark and Poole
Limited must have in place processes for identifying and addressing out-of-date, incorrect and redundant
personal data.

Principle 5: Storage Limitation. Personal data shall be 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. This
means Clark and Poole Limited must, wherever possible, store personal data in a way that limits or prevents
identification of the data subject.

Principle 6: Integrity & Confidentiality. Personal data shall be 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. Clark and Poole Limited must use appropriate technical
and organisational measures to ensure the integrity and confidentiality of personal data is maintained at all
times.

Principle 7: Accountability. The Data Controller shall be responsible for, and be able to demonstrate
compliance. This means Clark and Poole Limited must demonstrate that the six data protection principles
(outlined above) are met for all personal data for which it is responsible.

3.3. Data collection

3.3.1.Data Sources

Personal data should be collected only from the data subject unless one of the following apply:
 The nature of the business purpose necessitates collection of the personal data from other persons or
bodies.
 The collection must be carried out under emergency circumstances in order to protect the vital interests
of the data subject or to prevent serious loss or injury to another person.

If personal data is collected from someone other than the data subject, the data subject must be informed of
the collection unless one of the following apply:
 The data subject has received the required information by other means.
 The information must remain confidential due to a professional secrecy obligation
 A national law expressly provides for the collection, processing or transfer of the personal data.

Where it has been determined that notification to a data subject is required, notification should occur
promptly, but in no case later than:
 One calendar month from the first collection or recording of the personal data
 At the time of first communication if used for communication with the data subject
 At the time of disclosure if disclosed to another recipient.

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 3.3.2.Data subject consent
Each Clark and Poole Limited service/entity will obtain personal data only by lawful and fair means and,
where appropriate with the knowledge and consent of the individual concerned. Where a need exists to
request and receive the consent of an individual prior to the collection, use or disclosure of their personal
data, Clark and Poole Limited is committed to seeking such consent. The Data Protection Officer, in
cooperation with other relevant business representatives, shall establish a system for obtaining and
documenting data subject consent for the collection, processing, and/or transfer of their personal data.

3.3.3.Data subject Notification

Each Clark and Poole Limited service/entity will, when required by applicable law, contract, or where it
considers that it is reasonably appropriate to do so, provide data subjects with information as to the purpose
of the processing of their personal data. When the data subject is asked to give consent to the processing of
personal data and when any personal data is collected from the data subject, all appropriate disclosures will
be made, in a manner that draws attention to them, unless one of the following apply:
 The data subject already has the information;
 A legal exemption applies to the requirements for disclosure and/or consent. The disclosures may be
given orally, electronically or in writing. If given orally, the person making the disclosures should use a
suitable script or form approved in advance by the Data Protection Officer. The associated receipt or form
should be retained, along with a record of the facts, date, content, and method of disclosure.

3.3.4.External Privacy Notices

Each external website provided by Clark and Poole Limited will include an online ‘Privacy Notice’ and an
online ‘Cookie Notice’ fulfilling the requirements of applicable law.

3.4. Data Use

3.4.1.Data processing
Clark and Poole Limited uses the personal data of its contacts for the following broad purposes:
 The general running and business administration of Clark and Poole Limited services/entities.
 To provide services to Clark and Poole Limited’s stakeholders.
 The ongoing administration and management of customer services.
The use of a contact’s information should always be considered from their perspective and whether the use
will be within their expectations or if they are likely to object. For example, it would clearly be within a
contact’s expectations that their details will be used by Clark and Poole Limited to respond to a contact
request for information about the products and services on offer. However, it will not be within their
reasonable expectations that Clark and Poole Limited would then provide their details to third parties for
marketing purposes.
Each Clark and Poole Limited service/entity will process personal data in accordance with all applicable laws
and applicable contractual obligations. More specifically, Clark and Poole Limited will not process personal
data unless at least one of the following requirements are met:
 The data subject has given consent to the processing of their personal data for one or more specific
purposes.
 Processing is necessary for the performance of a contract to which the data subject is party or in order
to take steps at the request of the data subject prior to entering into a contract.
 Processing is necessary for compliance with a legal obligation to which the Data Controller is subject.
 Processing is necessary in order to protect the vital interests of the data subject 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 Data Controller.
 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 interests or fundamental rights and
freedoms of the data subject, in particular where the data subject is a child).

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 There are some circumstances in which personal data may be further processed for purposes that go
beyond the original purpose for which the personal data was collected. When making a determination as to
the compatibility of the new reason for processing, guidance and approval must be obtained from the Data
Protection Officer before any such processing may commence.
 In any circumstance where consent has not been gained for the specific processing in question, Clark
and Poole Limited will address the following additional conditions to determine the fairness and
transparency of any processing beyond the original purpose for which the personal data was collected:
Any link between the purpose for which the personal data was collected and the reasons for intended
further processing.
 The context in which the personal data has been collected, in particular regarding the relationship
between data subject and the Data Controller.
 The nature of the personal data, in particular whether special categories of data are being processed, or
whether personal data related to criminal convictions and offences are being processed.
 The possible consequences of the intended further processing for the data subject.
 The existence of appropriate safeguards pertaining to further processing, which may include encryption,
anonymisation or pseudonymisation.

3.4.2.Special Categories of Data

Clark and Poole Limited will only process special categories of data (also known as sensitive data) where the
data subject expressly consents to such processing or where one of the following conditions apply:
 The processing relates to personal data which has already been made public by the data subject.
 The processing is necessary for the establishment, exercise or defence of legal claims.
 The processing is specifically authorised or required by law.
 The processing is necessary to protect the vital interests of the data subject or of another natural person
where the data subject is physically or legally incapable of giving consent.
 Further conditions, including limitations, based upon national law related to the processing of genetic
data, biometric data or data concerning health.
In any situation where special categories of data are to be processed, prior approval must be obtained from
the Data Protection Officer, and the basis for the processing clearly recorded with the personal data in
question. Where special categories of data are being processed, Clark and Poole Limited will adopt
additional protection measures.

3.4.3.Children’s Data
Children under the age of 14 are unable to consent to the processing of personal data for information society
services (any service normally provided for payment, by electronic means and at the individual request of a
recipient of services). Consent must be sought from the person who holds parental responsibility over the
child. However, it should be noted that where processing is lawful under other grounds, consent need not be
obtained from the child or the holder of parental responsibility.

3.4.4.Data Quality
Each Clark and Poole Limited service/entity will adopt all necessary measures to ensure that the personal
data it collects and processes is complete and accurate in the first instance, and is updated to reflect the
current situation of the data subject. The measures adopted by Clark and Poole Limited to ensure data
quality include:
 Correcting personal data known to be incorrect, inaccurate, incomplete, ambiguous, misleading or
outdated, even if the data subject does not request rectification.
 Keeping personal data only for the period necessary to satisfy the permitted uses or applicable statutory
retention period.
 The removal of personal data if in violation of any of the data protection principles or if the personal data
is no longer required.
 Restriction, rather than deletion of personal data, insofar as:

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  a law prohibits erasure.
 erasure would impair legitimate interests of the data subject.
 the data subject disputes that their personal data is correct and it cannot be clearly ascertained
whether their information is correct or incorrect.

3.4.5.Profiling & Automated Decision Making

Clark and Poole Limited will only engage in profiling and automated decision-making where it is necessary to
enter into, or to perform, a contract with the data subject or where it is authorised by law. Where a Clark and
Poole Limited service/entity utilises profiling and automated decision-making, this will be disclosed to the
relevant data subjects. In such cases the data subject will be given the opportunity to:
 Express their point of view.
 Obtain an explanation for the automated decision.
 Review the logic used by the automated system.
 Supplement the automated system with additional data.
 Have a human carry out a review of the automated decision.
 Contest the automated decision.
Object to the automated decision-making being carried out. Each Clark and Poole Limited service/entity
must also ensure that all profiling and automated decision-making relating to a data subject is based on
accurate data.

3.4.6.Digital Marketing
As a general rule Clark and Poole Limited will not send promotional or direct marketing material to an Clark
and Poole Limited Contact through digital channels such as mobile phones, email and the Internet, without
first obtaining their consent. Any Clark and Poole Limited service/entity wishing to carry out a digital
marketing campaign without obtaining prior Consent from the data subject must first have it approved by the
Data Protection Officer. Where personal data processing is approved for digital marketing purposes, the data
subject must be informed at the point of first contact that they have the right to object, at any stage, to having
their data processed for such purposes. If the data subject puts forward an objection, digital marketing
related processing of their personal data must cease immediately and their details should be kept on a
suppression list with a record of their opt-out decision, rather than being completely deleted. It should be
noted that where digital marketing is carried out in a ‘business to business’ context, there is no legal
requirement to obtain an indication of Consent to carry out digital marketing to individuals provided that they
are given the opportunity to opt-out.

3.5. Data Retention

To ensure fair processing, personal data will not be retained by Clark and Poole Limited for longer than
necessary in relation to the purposes for which it was originally collected, or for which it was further
processed. The length of time for which Clark and Poole Limited services/entities need to retain personal
data is set out in Clark and Poole Limited ‘Data Retention Policy’. This takes into account the legal and
contractual requirements, both minimum and maximum, that influence the retention periods set forth in the
schedule. All personal data should be deleted or destroyed as soon as possible where it has been confirmed
that there is no longer a need to retain it.

3.6. Data Protection

Each Clark and Poole Limited service/entity will adopt physical, technical, and organisational measures to
ensure the security of personal data. This includes the prevention of loss or damage, unauthorised alteration,
access or processing, and other risks to which it may be exposed by virtue of human action or the physical
or natural environment. A summary of the personal data related security measures is provided below:
 Prevent unauthorised persons from gaining access to data processing systems in which personal data
are processed.
 Prevent persons entitled to use a data processing system from accessing personal data beyond their
needs and authorisations.

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  Ensure that personal data in the course of electronic transmission during transport cannot be read,
copied, modified or removed without authorisation.
 Ensure that access logs are in place to establish whether, and by whom, the personal data was
entered into, modified on or removed from a data processing system.
 Ensure that in the case where processing is carried out by a Data Processor, the data can be
processed only in accordance with the instructions of the Data Controller.
 Ensure that personal data is protected against undesired destruction or loss.
 Ensure that personal data collected for different purposes can and is processed separately.
 Ensure that personal data is not kept longer than necessary

3.7. Data subject Requests

The Data Protection Officer will establish a system to enable and facilitate the exercise of data subject rights
related to:
 Information access.
 Objection to processing.
 Objection to automated decision-making and profiling.
 Restriction of processing.
 Data portability.
 Data rectification.
 Data erasure. If an individual makes a request relating to any of the rights listed above
Clark and Poole Limited will consider each such request in accordance with all applicable data protection
laws and regulations. No administration fee will be charged for considering and/or complying with such a
request unless the request is deemed to be unnecessary or excessive in nature. data subjects are entitled to
obtain, based upon a request made in writing/email to the Data Protection Officer
(Natalie@clarkandpoole.co.uk)
It should be noted that situations may arise where providing the information requested by a data subject
would disclose personal data about another individual. In such cases, information must be redacted or
withheld as may be necessary or appropriate to protect that person’s rights. Detailed guidance for dealing
with requests from data subjects can be found in Clark and Poole Limited’s ‘Data Subject Access Rights
Policy and Procedure’ document.

3.8. Law Enforcement Requests & Disclosures

In certain circumstances, it is permitted that personal data be shared without the knowledge or consent of a
data subject. This is the case where the disclosure of the personal data is necessary for any of the following
purposes:
 The prevention or detection of crime.
 The apprehension or prosecution of offenders.
 The assessment or collection of a tax or duty.
 By the order of a court or by any rule of law.
If a Clark and Poole Limited service/entity processes personal data for one of these purposes, then it may
apply an exception to the processing rules outlined in this policy but only to the extent that not doing so
would be likely to prejudice the case in question. If any Clark and Poole Limited service/entity receives a
request from a court or any regulatory or law enforcement authority for information relating to an Clark and
Poole Limited contact, you must immediately notify the Data Protection Officer who will provide
comprehensive guidance and assistance.

3.9. Data Protection Training

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 All Clark and Poole Limited employees that have access to personal data will have their responsibilities
under this policy outlined to them as part of their staff induction training. In addition, each Clark and Poole
Limited service/entity will provide regular Data Protection training and procedural guidance for their staff.

3.10. Data Transfers

Clark and Poole Limited services/entities may transfer personal data to internal or third party recipients
located in another country where that country is recognised as having an adequate level of legal protection
for the rights and freedoms of the relevant data subjects. Where transfers need to be made to countries
lacking an adequate level of legal protection (i.e. third countries), they must be made in compliance with an
approved transfer mechanism. Clark and Poole Limited services/entities may only transfer personal data
where one of the transfer scenarios list below applies:
 The data subject has given Consent to the proposed transfer.
 The transfer is necessary for the performance of a contract with the data subject
 The transfer is necessary for the implementation of pre-contractual measures taken in response to the
data subject’s request.
 The transfer is necessary for the conclusion or performance of a contract concluded with a third party
in the interest of the data subject.
 The transfer is legally required on important public interest grounds.
 The transfer is necessary for the establishment, exercise or defence of legal claims.
 The transfer is necessary in order to protect the vital interests of the data subject

3.11. Complaints handling

Data subjects with a complaint about the processing of their personal data, should put forward the matter in
writing to the Data Protection Officer. An investigation of the complaint will be carried out to the extent that is
appropriate based on the merits of the specific case. The Data Protection Officer will inform the data subject
of the progress and the outcome of the complaint within a reasonable period. If the issue cannot be resolved
through consultation between the data subject and the Data Protection Officer, then the data subject may, at
their option, seek redress through mediation, binding arbitration, litigation, or via complaint to the Data
Protection Authority within the applicable jurisdiction.

3.12. Breach Reporting

Any individual who suspects that a personal data breach has occurred due to the theft or exposure of
personal data must immediately notify the Data Protection Officer providing a description of what occurred.
Notification of the incident can be made via e-mail, by calling, or by using the independent whistleblowing
line. The Data Protection Officer will investigate all reported incidents to confirm whether or not a personal
data breach has occurred. If a personal data breach is confirmed, the Data Protection Officer will follow the
relevant authorised procedure based on the criticality and quantity of the personal data involved. For severe
personal data breaches, Clark and Poole Limited Executive Team will initiate and chair an emergency
response team to coordinate and manage the personal data breach response.

4 ROLES AND RESPONSIBILITIES

4.1 Implementation
The management team of each Clark and Poole Limited service/entity must ensure that all Clark and Poole
Limited employees responsible for the processing of personal data are aware of and comply with the
contents of this policy. In addition, each Clark and Poole Limited service/entity will make sure all third parties
engaged to process personal data on their behalf (i.e. their data processors) are aware of and comply with
the contents of this policy. Assurance of such compliance must be obtained from all third parties, whether
companies or individuals, prior to granting them access to personal data controlled by Clark and Poole
Limited.

4.2 Support, Advice and Communication

For advice and support in relation to this policy, please contact the Data Protection Officer on 011804028971
or email the Data Protection Officer (Natalie@clarkandpoole.co.uk)

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5 REVIEW
This policy will be reviewed by the Data Protection Officer every three years, unless there are any changes
to regulations or legislation that would enable a review earlier.

6 RECORDS MANAGEMENT

Staff must maintain all records relevant to administering this policy and procedure in electronic form in a
recognised Clark and Poole Limited recordkeeping system.

All records relevant to administering this policy and procedure will be maintained for a period of 5 years.

7 TERMS AND DEFINITIONS

General Data Protection Regulation (GDPR): the General Data Protection Regulation (GDPR) (Regulation
(EU) 2016/679) is a regulation by which the European Parliament, the Council of the European Union and
the European Commission intend to strengthen and unify data protection for all individuals within the
European Union (EU). It also addresses the export of personal data outside the EU.

Data Controller: the entity that determines the purposes, conditions and means of the processing of
personal data.

Data Processor: the entity that processes data on behalf of the Data Controller.

Data Protection Authority: national authorities tasked with the protection of data and privacy as well as
monitoring and enforcement of the data protection regulations within the Union.

Data Protection Officer (DPO): an expert on data privacy who works independently to ensure that an entity
is adhering to the policies and procedures set forth in the GDPR.

Data subject: a natural person whose personal data is processed by a controller or processor.

personal data: any information related to a natural person or ‘data subject’, that can be used to directly or
indirectly identify the person.

Privacy Impact Assessment: a tool used to identify and reduce the privacy risks of entities by analysing the
personal data that are processed and the policies in place to protect the data.

Processing: any operation performed on personal data, whether or not by automated means, including
collection, use, recording, etc.

Profiling: any automated processing of personal data intended to evaluate, analyse, or predict data subject
behaviour.

Regulation: a binding legislative act that must be applied in its entirety across the Union.

Subject Access Right: also known as the Right to Access, it entitles the data subject to have access to and
information about the personal data that a controller has concerning them.

8 RELATED LEGISLATION AND DOCUMENTS

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  Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the
protection of natural persons with regard to the processing of personal data and on the free movement of
such data, and repealing Directive 95/46/EC (General Data Protection Regulation)

 The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data
protection and privacy for all individuals within the European Union. It addresses the export of personal
data outside the EU.

 Data Protection Act 2018

9 FEEDBACK AND SUGGESTIONS

Clark and Poole Limited employees may provide feedback and suggestions about this document by emailing
the Data Protection Officer (Natalie@clarkandpoole.co.uk)

10 APPROVAL AND REVIEW DETAILS

Approval and Review Details

Approval Authority Board of Directors
Data Protection Officer Natalie Addy
Next Review Date 25/5/2019]

Approval and Amendment Details

History
Original Approval Authority and Date Joanne Clark 25/5/18
Amendment Authority and Date

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