Applied Thermal Control Ltd
Data Protection Policy
1.1 Applied Thermal Control Ltd recognises its’ responsibilities in complying
with the General Data Protection Regulation (GDPR).
1.2 This Policy sets out the requirements to ensure compliance with laws
and regulations applicable to the collection, storage, use, processing and
transfer of personal data. It applies to all staff and agency employees, and
all suppliers and clients who receive personal data from the Company, have
access to personal data collected or processed by the Company, or who provide
information to the Company.
1.3 ‘Personal data’ means 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
2.1 The Company’s data protection is the responsibility of the Sales and
Marketing manager under the title Data Protection Officer (DPO).
2.2 The DPO will determine and recommend to the Board the procedures and
controls to ensure compliance.
2.2.1 The DPO will ensure that suitable training and guidance is
provided to data processors.
2.2.3 The DPO will establish procedures and standard contractual
provisions for obtaining compliance with this Policy by customers, suppliers,
and third parties who receive personal data from the Company, have access to personal
data collected or processed by the Company, or who provide information to the
2.2.4 The DPO will establish periodic compliance audits.
2.2.5 The DPO will establish processes for responding to Data Subject
2.2.6 The DPO will establish processes for disclosure to the relevant
authorities and Data Subjects of any loss of personal data.
2.2.7 The DPO will inform the Board of the potential penalties for
non-compliance with Data Protection laws.
2.2.8 The DPO will ensure that effective risk management plans in
relation to Data Protection are in place.
3. Data Protection Principles
3.1 Personal data shall be:
3.1.1 processed lawfully, fairly and in a transparent manner in relation
to the data subject (‘lawfulness, fairness and transparency’);
3.1.2 collected for specified, explicit and legitimate purposes and not
further processed in a manner that is incompatible with those purposes; further
processing for archiving purposes in the public interest, scientific or
historical research purposes or statistical purposes shall, in accordance
with Article 89(1), not be considered to be
incompatible with the initial purposes (‘purpose limitation’);
3.1.3 adequate, relevant and limited to what is necessary in relation to
the purposes for which they are processed (‘data minimisation’);
3.1.4 accurate and, where necessary, kept up to date; every reasonable
step must be taken to ensure that personal data that are inaccurate, having
regard to the purposes for which they are processed, are erased or rectified
without delay (‘accuracy’);
3.1.5 kept in a form which permits identification of data subjects for
no longer than is necessary for the purposes for which the personal data are
processed; personal data may be stored for longer periods insofar as the
personal data will be processed solely for archiving purposes in the public
interest, scientific or historical research purposes or statistical purposes in
accordance with Article 89(1) subject to implementation of the appropriate
technical and organisational measures required by this Regulation in order to
safeguard the rights and freedoms of the data subject (‘storage limitation’);
3.1.6 processed in a manner that ensures appropriate security of the
personal data, including protection against unauthorised or unlawful processing
and against accidental loss, destruction or damage, using appropriate technical
or organisational measures (‘integrity and confidentiality’).
3.2 The controller shall be responsible for, and be able to demonstrate
compliance with, paragraph 3.1 (‘accountability’).
4.1 The Company shall document
the personal data it holds, where it came from, how it is collected and with
whom it is shared.
4.2 The Company will organise such
information audits as are required to ensure compliance.
4.3 The Company will ensure extra
safeguards for the processing of any “special categories” of personal data,
including genetic and biometric where processed to uniquely identify an
5. Communicating Privacy Information
5.1 The Company will provide such
Privacy Notices to ensure Data Subjects are aware of:
5.1.1 what it is going to do with their
5.1.2 who it will be shared
5.1.3 the lawful basis for processing the data;
5.1.4 the data retention
5.1.5 their right to complain to the
Information Commissioner’s Office if they think there is a problem with the way
the data is being handled.
6.1 The Company shall ensure
6.1.1 data subjects
are provided with a clear explanation of the processing to which they are
6.1.2 the consent
mechanism is genuinely of a voluntary and "opt-in" nature;
6.1.3 data subjects are
permitted to withdraw their consent easily;
6.1.4 it does not rely on
silence or inactivity to collect consent (e.g., pre‑ticked boxes do not
constitute valid consent);
6.1.5 wherever it relies
on the consent of EU employees as a lawful basis for processing personal data,
the it will consider whether such consent is freely given.
7. Data Subject Rights
7.1 The GDPR provides rights for Data
Subjects, in particular:
7.1.1 to be informed of
information held about them;
7.1.2 to access information held
7.1.3 to rectify the information
held on them;
7.1.4 to erase information held
7.1.5 to restrict the processing
of the personal data;
7.1.6 to data portability;
7.1.7 to object to the personal
data held about them;
7.1.8 not to be subject to
automated decision-making including profiling.
8. Subject Access Requests
8.1 The Company shall implement
processes for responding to ensure Subject Access Requests in line with the
required timescale (one month).
8.2 The Company will consider the
nature of requests made and respond accordingly.
8.3 The Company may refuse charge
for or requests that are manifestly unfounded or excessive, informing the
individual why and advising that they have the right to Information
9. Data Breaches
9.1 The Company will
ensure that it has in place procedures in place to detect, report and investigate
a personal data breach.
10. Policy Reviews
10.1 This Policy
shall be reviewed at such frequencies as are determined by the Board or when
necessitated by legislation.
DPO Ryan Watson