This Data Protection Policy applies to Ralawise group companies conducting business in the UK and within the European Economic Area (EEA) or processing the Personal Data of our customers, suppliers, employees, workers and other third parties in the UK or within EEA (as applicable) (the details of Ralawise group companies can be found in the Schedule) (hereinafter referred to as “Ralawise”, ‘we’ or ‘us’ or ‘our’). We strive to comply with applicable laws and regulations related to Personal Data protection in countries where Ralawise operates.

This Data Protection Policy sets out the basic principles by which Ralawise handles the personal data of consumers, customers, suppliers, business partners, employees and other individuals, and indicates the responsibilities of its business departments, employees and others while processing personal data.   

The users of this document are Ralawise Personnel (“you”, “your”). You must read, understand and comply with this Data Protection Policy when Processing Personal Data on our behalf and attend training on its requirements. This Data Protection Policy sets out what we expect from you for Ralawise to comply with applicable law. Your compliance with this Data Protection Policy is mandatory. Any breach of this Data Protection Policy may result in disciplinary action.

This Data Protection Policy applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject.

When we say ‘Ralawise’, ‘we’ or ‘us’ or ‘our’ in this privacy notice, we may be referring to the whole of the Ralawise group, or the separate and distinct legal entities that make up the Ralawise group (which will depend on the context). It also includes any other businesses we add to this group in the future.

• Definitions:

• Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject's wishes by which they, by a statement or by a clear positive action, signify agreement to the Processing of Personal Data relating to them.
• Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the Data Protection Legislation. Ralawise may determine from time to time which Ralawise group company is the Controller of Personal Data relating to our Ralawise Personnel and Personal Data used in our business for our own commercial purposes.
• Criminal Convictions Data: means personal data relating to criminal convictions and offences and includes personal data relating to criminal allegations and proceedings.
• Data Protection Legislation:

1. a) To the extent the UK GDPR applies, the law of the United Kingdom or of a part of the United Kingdom which relates to the protection of personal data.
2. b) To the extent the EU GDPR applies, the law of the European Union or any member state of the European Union to which the relevant Ralawise entity is subject, which relates to the protection of personal data.

• EU GDPR: the General Data Protection Regulation ((EU) 2016/679).
• UK GDPR: the retained EU law version of the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the UK GDPR.
• Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.
• Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programmes involving the Processing of Personal Data.
• Explicit Consent: consent which requires a very clear and specific statement (that is, not just action).
• Information Security Manager (ISM): a data protection manager with responsibility for data protection compliance. The ISM can be contacted by email to data.security@ralawise.com or in writing to Ralawise Ltd, Unit 112, Tenth Avenue, Zone 3, Deeside Industrial Park, Deeside, Flintshire, CH5 2UA.
• Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person's actions or behaviour.
• Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.
• Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the Data Protection Legislation.
• Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies: separate notices which Ralawise may put in place from time to time, setting out information that may be provided to Data Subjects when Ralawise collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, employee privacy notices or the website privacy policy) or they may be stand-alone, one-time privacy statements covering Processing related to a specific purpose. This includes, without limitation, Ralawise Privacy Policy available at the following link.
• Processing or Process: any activity that involves the use of Personal 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 transmitting or transferring Personal Data to third parties.
• Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.
• Ralawise Personnel: all employees, workers, contractors, agency workers, consultants, directors, members and others.
• Special Categories of Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.

We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times. Ralawise may be exposed to substantial fines for failure to comply with the provisions of the Data Protection Legislation.

The responsibility for ensuring appropriate personal data processing lies with all Ralawise Personnel who has access to personal data processed by Ralawise.

The key areas of responsibilities for processing personal data lie with the following organisational roles:

The board of directors makes decisions about and approves Ralawise’s general strategies on personal data protection.

The ISM is the nominated person responsible for data protection matters. Responsible for managing the personal data protection programme and for the development and promotion of end-to-end personal data protection policies.

The ISM monitors and analyses personal data laws and changes to regulations, develops compliance requirements, and assists business departments in achieving their personal data goals. This may include seeking legal advice or external counsel.

The ISM is responsible for passing on personal data protection responsibilities to suppliers and improving suppliers' awareness levels of personal data protection as well as flow down personal data requirements to any third party a supplier they are using. The Procurement Department must ensure that Ralawise reserves a right to audit suppliers.

Chief Technology Officer is responsible for:

• Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
• Performing regular checks and scans to ensure security hardware and software is functioning properly.

The Head of Marketing, is responsible for:

• Approving any data protection statements attached to communications such as emails and letters.
• Addressing any data protection queries from journalists or media outlets like newspapers.
• Where necessary, working with the ISM to ensure marketing initiatives abide by data protection principles.

The Head of Human Resources is responsible for:

• Improving all employees' awareness of user personal data protection.
• Organising Personal Data protection expertise and awareness training for employees working with personal data.
• End-to-end employee personal data protection. It must ensure that employees' personal data is processed based on the employer's legitimate business purposes and necessity.

We adhere to the principles relating to Processing of Personal Data set out in the Data Protection Legislation which require Personal Data to be:

• Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency);
• collected only for specified, explicit and legitimate purposes (Purpose Limitation);
• adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation);
• accurate and where necessary kept up to date (Accuracy);
• not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation);
• Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality);
• not transferred to another country without appropriate safeguards being in place (Transfer Limitation); and
• made available to Data Subjects and allow Data Subjects to exercise certain rights in relation to their Personal Data (Data Subject's Rights and Requests).

We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).

• Lawfulness and fairness

Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject.

You may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The Data Protection Legislation restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.

The Data Protection Legislation allows Processing for specific purposes, some of which are set out below:

• the Data Subject has given his or her Consent;
• the Processing is necessary for the performance of a contract with the Data Subject;
• to meet our legal compliance obligations;
• to protect the Data Subject's vital interests; or
• to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices.

You must identify and document the legal ground being relied on for each Processing activity.

A Controller must only process Personal Data on the basis of one or more of the lawful bases set out in the Data Protection Legislation, which include Consent.

A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters.

Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured. Consent may need to be refreshed if you intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented.

You will need to evidence Consent captured and keep records of all Consents so that Ralawise can demonstrate compliance with Consent requirements.

The Data Protection Legislation requires Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. The information must be provided through appropriate Privacy Notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them.

Whenever we collect Personal Data directly from Data Subjects, including for human resources or employment purposes, we must provide the Data Subject with all the information required by the Data Protection Legislation including the identity of the Controller, how and why we will use, Process, disclose, protect and retain that Personal Data through a Privacy Notice which must be presented when the Data Subject first provides the Personal Data.

When Personal Data is collected indirectly (for example, from a third party or publicly available source), we must provide the Data Subject with all the information required by the Data Protection Legislation as soon as possible after collecting or receiving the data. We must also check that the Personal Data was collected by the third party in accordance with the Data Protection Legislation and on a basis which contemplates our proposed Processing of that Personal Data.

If you are collecting Personal Data from Data Subjects, directly or indirectly, then you must provide Data Subjects with a Privacy Notice.

Personal Data must be collected only for specified, explicit and legitimate purposes. It must not be further Processed in any manner incompatible with those purposes.

You cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes and they have Consented where necessary.

Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.

You may only Process Personal Data when performing your job duties requires it. You cannot Process Personal Data for any reason unrelated to your job duties.

You may only collect Personal Data that you require for your job duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes.

You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with Ralawise's data retention guidelines as set out in our Data Retention Schedule.

Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.

You will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.

You must not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.

You will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with our Data Retention Schedule. This includes requiring third parties to delete that data where applicable.

We must ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice.

Protecting Personal Data

Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. Ralawise and Ralawise Personnel are responsible for protecting the Personal Data we hold. You must implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data which you process and against the accidental loss of, or damage to, such Personal Data.

We do not, as a rule, process Special Categories of Persona Data or Criminal Convictions Data. In the unlikely event that you process such data, you must exercise particular care in protecting such data from loss and unauthorised access, use or disclosure.

You must follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction, including as set out in our Privacy Policy. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.

You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

• Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it;
• Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed; and
• Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.

You must comply with and not attempt to circumvent the administrative, physical and technical safeguards we implement and maintain in accordance with the Data Protection Legislation and relevant standards to protect Personal Data.

The Data Protection Legislation requires Controllers to notify any Personal Data Breach to the data protection authorities and, in certain instances, the Data Subject.

We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.

If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the ISM. You should preserve all evidence relating to the potential Personal Data Breach.

The Data Protection Laws restrict data transfers to countries outside the UK and the European Economic Area (the “EEA”) (depending on where personal data originates) to ensure that the level of data protection afforded to individuals by the relevant Data Protection Law is not undermined. You transfer personal data originating in one country across borders when you transmit, send, view or access that data in or to a different country.

Transfer of personal data between the UK and the EEA is a cross border transfer.

You may only transfer personal data outside the UK or the EEA (as the case may be) if one of the following conditions applies:

• the UK or the EEA (as applicable) has issued regulations confirming that the country to which we transfer the personal data ensures an adequate level of protection for the data subject's rights and freedoms;
• appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved for use in the UK or the EEA (as applicable), an approved code of conduct or a certification mechanism;
• the data subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or

the transfer is necessary for one of the other reasons set out in the relevant Data Protection Law including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest.

Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:

• withdraw Consent to Processing at any time;
• receive certain information about the Controller's Processing activities;
• request access to their Personal Data that we hold;
• prevent our use of their Personal Data for direct marketing purposes;
• ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;
• restrict Processing in specific circumstances;
• challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;
• request a copy of an agreement under which Personal Data is transferred outside of the UK or the EEA (as the case may be);
• prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;
• be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;
• make a complaint to the supervisory authority; and
• in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine-readable format.

You must verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade you into disclosing Personal Data without proper authorisation).

You must immediately forward any Data Subject request you receive to the ISM.

We, as the Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.

Ralawise must have adequate resources and controls in place to ensure and to document Data Protection Legislation compliance.

The Data Protection Legislation requires us to keep full and accurate records of all our data Processing activities.

You must keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects' Consents and procedures for obtaining Consents in accordance with Ralawise’s record-keeping guidelines as set out in our Data Retention Schedule.

These records should include, at a minimum, the name and contact details of the Controller, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data's retention period and a description of the security measures in place. To create the records, data maps should be created which should include the detail set out above together with appropriate data flows.

Where applicable, we will provide Ralawise Personnel adequate training to enable them to comply with data privacy laws. We must regularly test our systems and processes to assess compliance.

You must undergo all mandatory data privacy related training and (where you are responsible for a department or a team) ensure your team undergo similar mandatory training.

You must regularly review all the systems and processes under your control to ensure they comply with this Data Protection Policy and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.

We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles.

You must assess what Privacy by Design measures can be implemented on all programmes, systems or processes that Process Personal Data by taking into account the following:

• the state of the art;
• the cost of implementation;
• the nature, scope, context and purposes of Processing; and
• the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing.

Controllers must also conduct DPIAs in respect to high-risk Processing.

You should conduct a DPIA (and discuss your findings with the ISM) when implementing major system or business change programs involving the Processing of Personal Data including use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes).

A DPIA must include:

• a description of the Processing, its purposes and the Controller's legitimate interests if appropriate;
• an assessment of the necessity and proportionality of the Processing in relation to its purpose;
• an assessment of the risk to individuals; and
• the risk mitigation measures in place and demonstration of compliance.

We are subject to certain rules and privacy laws when marketing to our customers.

For example, a Data Subject's prior Consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as "soft opt-in" allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.

The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information.

A Data Subject's objection to direct marketing must be promptly honoured. If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.

Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.

You may only share the Personal Data we hold with another employee, agent or representative of our group (which includes our subsidiaries and our ultimate holding company along with its subsidiaries) if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions (see section 14 – Transfer Limitations).

You may only share the Personal Data we hold with third parties, such as our service providers, if:

• they have a need to know the information for the purposes of providing the contracted services;
• sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject's Consent has been obtained;
• the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
• the transfer complies with any applicable cross-border transfer restrictions; and
• a fully executed written contract that contains Data Protection Legislation-approved third party clauses has been obtained.

We keep this Data Protection Policy under regular review. This version was last updated on 1 September 2021. Historic versions can be obtained by contacting us.

This Data Protection Policy does not override any applicable national data privacy laws and regulations in countries where Ralawise operates.