KEFCO PRIVACY POLICY

KEFCO GROUP

Kefco in reference to the privacy policy refers to the group of companies listed below

Company No.		Company Name
4736600		J&J Restaurants Limited
1043591		Kefco Sales Limited
10692949		Chelcol Limited

WHAT IS GDPR? (GENERAL DATA PROTECTION REGULATION)

GDPR is the EU's new data protection regulation, designed to harmonise the data privacy laws across Europe. It is the most important change in data privacy regulation in the last 20 years.

It applies to all businesses that collect data from or monitor the behaviour of EU residents, meaning it not only applies to EU businesses, but businesses in any country worldwide who deal with the data of EU residents. Businesses worldwide are required to collect data more securely.

PREPARING FOR GDPR

Kefco is committed to ensuring the protection of personal data

As a company the amount of personal data stored is relatively limited due to our systems being managed by our franchisor, however even with the small amount of data we store major developments have had to be made to protect and adhere to the enhanced regulation.

Kefco have reviewed all internal systems that are used by:

· Internal staff

· Suppliers

· Franchisees

· Franchisors

· Consultants

· Service providers

· 3rd party applications

CONTACTING US

We welcome any queries, comments or requests you may have regarding our Privacy Policy.

Contact our Data Protection Officer who is on Kefco’s Board of Directors by emailing: gdpr@kefco.uk or Tel: 01702 425100

OTHER PAGES WITHIN THIS SECTION

Our Commitment to GDPR

Privacy Notice

Data Protection Policy

Data Security Policy

Data Retention Policy

Data Transfers Policy

Subject Access Request

PRIVACY NOTICE

DEFINITION

Kefco in reference to the privacy policy refers to the group of companies listed below

Company No.		Company Name
4736600		J&J Restaurants Limited
1043591		Kefco Sales Limited
10692949		Chelcol Limited

INTRODUCTION

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

Kefco is pleased to provide the following Privacy Notice:

PERSONAL DATA

Kefco uses the information collected from you to maintain employer, customer, and supplier records to facilitate an ongoing working relationship.

Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. Kefco may from time to time use such information to identify its visitors. Kefco may also collect statistics about the behaviour of visitors to its website.

Kefco website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Kefco website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Kefco website.

Any information Kefco holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers such as credit referencing agencies.

Kefco will only collect the information needed so that it can provide you with the services expected as an employer, supplier or customer.

LEGAL BASIS FOR PROCESSING ANY PERSONAL DATA

Maintain and manage employee information for Training, Payroll, Human Resources and legislation needs. To manage customer and supplier data for accounting and marketing purposes including customer services.

LEGITIMATE INTERESTS PURSUED BY KEFCO

To promote the marketing of products and services and offered by Kefco and its franchisor.

CONSENT

By accepting to be employed and trade with Kefco, you are agreeing to allow the personal data to be used for the purposes outlined. You can withdraw consent at any time by emailing gdpr@kefco.uk or writing to us, see last section for full contact details.

DISCLOSURE

Kefco may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. Kefco requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.

Kefco do not broker or pass on information gained from your engagement. However, Kefco may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The company may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Kefco, its clients and/or the wider community.

RETENTION POLICY

Data Type	Detail	Data storage Type	Retention Period
Payroll and Human Resource Information
	Payslips, time sheets, Attendance records		3 years from tax year end
	P60, P32, P45 information including start and leave date, National Insurance Number, Fit notes for Statutory Sick Pay purposes, Maternity/Paternity disclosures, Notice of Coding (tax Code) At the time of writing a full 6 years of this information is required to be kept for statutory/legal purposes.	E	7 years
	Final contact address, Final Grade within payroll system, email address		7 from leaving date
	Copies of Identification collected, Eligibility to work in UK,	E	7 years from leaving date
	Health and safety reports,	E	3 years
	Application form and supporting documents (excluding ID) , resignation letter.	E & P	3 years from leaving date
	Disciplinary records	E	3 Years
	Other payroll records	E & P	3 years


Supplier Information
	Invoices and credit notes	P & E	7 Years
	Address and telephone numbers and contact names and business email addresses of the suppliers employees	E	7 Years

Tenant Information
	Tenant references	P & E	3 Years
	Tenant contract to lease	P & E	7 years
	Tenant name and period of tenancy	P & E	7 years
	Forwarding address	P & E	1 year



Kefco Customers	(Non KFC Customers)
	Invoices and credit notes	P & E	7 years
	Name and contact details	P & E	7 Years



KFC Customers
Customer service contacts	Name, address and contact telephone numbers and email addresses	P & E	1 year
Health and safety Records	Name address and contact details and potential insurance claims, CCTV.	P & E	3 Years
Claims	Name, address, incident details & CCTV	P & E	1 year after settlement of dispute

CCTV	Safety recordings (regular)	E	Up to 31days
	Copies of data taken from recordings Dependant on purpose.	E	Up to 3 Years unless a dispute arises then 1 year from dispute resolution.

DATA STORAGE

Employees should refer to the company handbook regarding data storage and its use.

Other data is held on servers in the UK.

YOUR RIGHTS AS A DATA SUBJECT

At any point whilst Kefco is in possession of or processing your personal data, all data subjects have the following rights:

· Right of access – you have the right to request a copy of the information that we hold about you.

· Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

· Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

· Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.

· Right of portability – you have the right to have the data we hold about you transferred to another organisation.

· Right to object – you have the right to object to certain types of processing such as direct marketing.

· Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Kefco refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

Kefco at your request can confirm what information it holds about you and how it is processed

YOU CAN REQUEST THE FOLLOWING INFORMATION:

· Identity and the contact details of the person or organisation (Kefco) that has determined how and why to process your data.

· Contact details of the Board of Directors, where applicable.

· The purpose of the processing as well as the legal basis for processing.

· If the processing is based on the legitimate interests of Kefco or a third party such as one of its suppliers or franchisor, information about those interests.

· The categories of personal data collected, stored and processed.

· Recipient(s) or categories of recipients that the data is/will be disclosed to.

· How long the data will be stored.

· Details of your rights to correct, erase, restrict or object to such processing.

· Information about your right to withdraw consent at any time.

· How to lodge a complaint with the supervisory authority (Data Protection Regulator).

· Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

· The source of personal data if it wasn’t collected directly from you.

· Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

TO ACCESS WHAT PERSONAL DATA IS HELD, IDENTIFICATION WILL BE REQUIRED

Kefco will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Kefco is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to gdpr@kefco.uk or writing to us at the address further below.

COMPLAINTS

In the event that you wish to make a compliant about how your personal data is being processed by Kefco or its partners, you have the right to complain to the Kefco board of directors. If you do not get a response within 30 days you can complain to the Data Protection Regulator.

The details for each of these contacts are:

Kefco, attention of the Board of Directors

Kefco House, Cherry Orchard Way, Rochford SS4 1GP

or email gdpr@kefco.uk

Data Protection Regulator Website: https://ico.org.uk/

OTHER PAGES WITHIN THIS SECTION

Our Commitment to GDPR

Privacy Notice

Data Protection Policy

Data Security Policy

Data Retention Policy

Data Transfers Policy

Subject Access Request

DATA PROTECTION POLICY

Kefco and subsidiaries companies will hereafter be referred to as “Kefco”

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 Kefco employees and all third parties responsible for the processing of persona data on behalf of Kefco services/entities.

3. POLICY STATEMENT

Kefco 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 Kefco employees and third parties in relation to the collection, use, retention, transfer, disclosure and destruction of any personal data belonging to a Kefco 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. Kefco, as a Data Controller, is responsible for ensuring compliance with the data protection requirements outlined in this policy. Non-compliance may expose Kefco to complaints, regulatory action, fines and/or reputational damage.

Kefco leadership is fully committed to ensuring continued and effective implementation of this policy and expects all Kefco 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 DATA PROTECTION PRINCIPLES

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

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, Kefco 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 Kefco 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 Kefco 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 Kefco 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 Kefco 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. Kefco 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 must demonstrate that the six data protection principles (outlined above) are met for all personal data for which it is responsible.

3.2 DATA COLLECTION

3.2.1. 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.

· The data subject already has the information;

· A legal exemption applies to the requirements for disclosure and/or consent. The disclosures may be given electronically or in writing. The associated receipt or form should be retained, along with a record of the facts, date, content, and method of disclosure.

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.

3.2.2. DATA SUBJECT CONSENT

Each Kefco 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, Kefco is committed to seeking such consent. The Board of Directors, 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.

3.2.3. DATA SUBJECT NOTIFICATION

Each Kefco 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:

3.2.4. EXTERNAL PRIVACY NOTICES

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

3.3 DATA USE

3.4.1. DATA PROCESSING

Kefco uses the personal data of its contacts for the following broad purposes:

· The general running and business administration of Kefco services/entities.

· To provide services to Kefco 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 Kefco 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 Kefco would then provide their details to third parties for marketing purposes.

Each Kefco service/entity will process personal data in accordance with all applicable laws and applicable contractual obligations. More specifically, Kefco 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).

· In any circumstance where consent has not been gained for the specific processing in question, Kefco 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.

· 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:

o a law prohibits erasure.

o erasure would impair legitimate interests of the data subject.

o the data subject disputes that their personal data is correct and it cannot be clearly ascertained whether their information is correct or incorrect.

· 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.

· 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

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 will be obtained from Board of Directors before any such processing may commence.

3.4.2 SPECIAL CATEGORIES OF DATA

Kefco processes sensitive data of employees in the course of its business. Where sensitive data is being processed, Kefco will adopt additional protection measures. Kefco does not process sensitive data of any other party.

3.4.3 CHILDREN’S DATA

Persons/Children under the age of 16 are not permitted to access the Kefco systems and services or have access to customer data. Data on children will only be retained should an incident occur within a restaurant for which we are responsible for recording said incident. I.e a health and safety issue.

3.4.4 DATA QUALITY

Each Kefco 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 Kefco to ensure data quality include:

3.4.5. PROFILING & AUTOMATED DECISION MAKING

Kefco 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 Kefco 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.

· 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.

· 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

· 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

Object to the automated decision-making being carried out. Each Kefco 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 Kefco will not send promotional or direct marketing material to a Kefco Contact through digital channels such as mobile phones, email and the Internet, without first obtaining their consent. Any Kefco service/entity wishing to carry out a digital marketing campaign without obtaining prior Consent from the data subject must first have it approved by a Board of Directors. 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.

3.4 DATA RETENTION

To ensure fair processing, personal data will not be retained by Kefco 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 Kefco services/entities need to retain personal data is set out in Kefco ‘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.

3.5 DATA PROTECTION

Each Kefco 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:

3.6 DATA SUBJECT REQUESTS

Kefco will establish a system to enable and facilitate the exercise of data subject rights related to:

Kefco will consider each such request in accordance with all applicable data protection laws and regulations. A fee of £10.00 will be charged for considering and/or complying with such a request data subjects are entitled to obtain, based upon a request made in writing/email to: gdpr@kefco.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 Kefco ‘Data Subject Access Rights Policy and Procedure’ document.

3.7 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:

If a Kefco 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 Kefco service/entity receives a request from a court or any regulatory or law enforcement authority for information relating to a Kefco contact, you must immediately notify the Board of Directors who will provide comprehensive guidance and assistance.

3.8 DATA PROTECTION TRAINING

All Kefco 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 Kefco service/entity will provide regular Data Protection training and procedural guidance for their staff.

3.9 DATA TRANSFERS

Kefco 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. Kefco services/entities may only transfer personal data where one of the transfer scenarios list below applies:

3.10 COMPLAINTS HANDLING

Data subjects with a complaint about the processing of their personal data, should put forward the matter in writing gdpr@kefco.uk. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case. The Board of Directors 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 Kefco, 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.

3.11 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 gdpr@kefco.uk providing a description of what occurred. Kefco will investigate all reported incidents to confirm whether or not a personal data breach has occurred. If a personal data breach is confirmed, Kefco will follow the relevant authorised procedure based on the criticality and quantity of the personal data involved. For severe personal data breaches, Kefco’s Directors 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 Kefco service/entity must ensure that all Kefco employees responsible for the processing of personal data are aware of and comply with the contents of this policy. In addition, each Kefco 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 Kefco.

5 REVIEW

This policy will be reviewed by the Board of Directors 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 Kefco 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

· 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)

9 FOR MORE INFORMATION

Contact our Data Protection Officers who are the Kefco Board of Directors by emailing: gdpr@kefco.uk

10 APPROVAL AND REVIEW DETAILS

Approval and Review	Details
Approval Authority	Board of Directors
Next Review Date	25/05/2019

Approval and Amendment History	Details
Original Approval Authority and Date	Board of Directors 25/05/2018

DATA SECURITY POLICY

DEFINITION

Kefco and subsidiaries companies will hereafter be referred to as “Kefco”

1 PURPOSE

This policy establishes an effective, accountable and transparent framework for ensuring high standards of data security at Kefco.

2 SCOPE

This policy applies across all entities or subsidiaries owned, controlled, or operated by Kefco and to all employees, including part-time, temporary, or contract employees.

3 POLICY STATEMENT

PHYSICAL SECURITY

The Kefco head office is secured by controlled access by key fob, and other security measures e.g. alarms and keyholder attendance. Personal Data in the restaurant offices is secured under lock and key when not in use accessible by management on site.

Important documents are stored in cabinets that can only be accessed by pre-authorised individuals. Fire alarms are in place to detect and mitigate damage in the unlikely event of a fire. Regular fire drills are also conducted by the premises management team to educate employees about emergency evacuation procedures. A policy has been implemented to approve and regulate visitor access to the building.

Kefco hosts its application and data in industry-leading AWS Cloud Services, whose data centres have been thoroughly tested for security, availability and business continuity.

APPLICATION SECURITY

All of Kefco applications are hosted on local servers or within a Microsoft platform. Kefco uses the resources of a local IT Support company to ensure the data on local servers is protected.

APPLICATION ARCHITECTURE

The application is initially protected by a firewall. The application can be accessed only by users with valid credentials.

DATA SECURITY

Kefco takes the protection and security of its data very seriously.

Regular back ups are taken of all data are taken each night.

4 RESPONSIBILITIES

REGULATORY COMPLIANCE

All formal processes and security standards at Kefco are designed to meet regulations at the industry, state and European Union levels.

REPORTING ISSUES AND THREATS

If you have found any issues or flaws impacting the data security or privacy of Kefco users, please write to gdpr@kefco.uk with the relevant information so we can get working on it right away.

Your request will be looked into immediately. We might ask for your guidance in identifying or replicating the issue and understanding any means to resolving the threat right away. Please be clear and specific about any information you give us. We deeply appreciate your help in detecting and fixing flaws in Kefco’s systems and will acknowledge your contribution to the world once the threat is resolved.

RECORDS MANAGEMENT

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

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

5 TERMS AND DEFINITIONS

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

6 RELATED LEGISLATION AND DOCUMENTS

· Kefco Data Protection Policy

7 FOR MORE INFORMATION

Contact our Data Protection Officers who are the Kefco Board of Directors by emailing: gdpr@worldoptions.co.uk

7 APPROVAL AND REVIEW DETAILS

Approval and Review	Details
Approval Authority	Board of Directors
Next Review Date	25/05/2019

Approval and Amendment History	Details
Original Approval Authority and Date	Board of Directors 25/05/2018
Amendment Authority and Date

OTHER PAGES WITHIN THIS SECTION

Our Commitment to GDPR

Privacy Notice

Data Protection Policy

Data Security Policy

Data Retention Policy

Data Transfers Policy

Subject Access Request

DATA RETENTION POLICY

DEFINITION

Kefco and subsidiaries companies will hereafter be referred to as “Kefco”

1 PURPOSE

The purpose of this policy is to specify Kefco guidelines for retaining different types of personal data.

2 SCOPE

The scope of this policy covers all Kefco personal data stored on company-owned, company-leased, and otherwise company-provided systems and media, regardless of location. These records may be created, received or maintained in hard copy or electronically.

3 POLICY STATEMENT

The need to retain personal data varies widely with the type of data. Some personal data can be immediately deleted and some must be retained until reasonable potential for future need no longer exists. This Data Retention Policy provides guidelines to ensure that all applicable regulations and Kefco rules on personal data retention are consistently applied throughout the organisation.

Reasons for data retention

Some personal data must be retained in order to protect the company's interests, comply with regulatory requirements, preserve evidence, and generally conform to good business practices. Personal data may be retained for one or several of the following reasons:

· Business requirements

· Regulatory requirements

· Possible litigation

· Accident investigation

· Security incident investigation

· Intellectual property preservation

RETENTION PERIODS

Different types of data will be retained for different periods of time:

· Personal customer data: Personal data will be held for as long as the individual is a customer of the company plus 7 years.

· Personal employee data: General employee data will be held for the duration of employment and then for 7 years after the last day of contractual employment. Employee contracts will be held for 7 years after last day of contractual employment.

· Personal tax payments will be held for 4 years.

· Records of leave will be held for 7 years.

· Recruitment details: Interview notes of unsuccessful applicants will be held for 6 months after interview. This personal data will then be destroyed.

· Operational data: Most company data will fall in this category. Operational data will be retained for 6+ years.

· Critical data including Tax and VAT: Critical data must be retained for 7 years.

For more details, please refer to Appendix 1 – Data Retention Schedule

RETENTION OF ENCRYPTED DATA

If any information retained under this policy is stored in an encrypted format, considerations must be taken for secure storage of the encryption keys. Encryption keys must be retained as long as the data that the keys decrypt is retained.

DATA DUPLICATION

When identifying and classifying Kefco personal data, it is important to also understand where that data may be stored, particularly for duplicate copies, so that this policy may be applied to all duplicates of the information.

DATA DESTRUCTION

When the retention timeframe expires, Kefco will actively destroy the data covered by this policy. If a user feels that certain data should not be destroyed, he or she should identify the data to his or her supervisor so that an exception to the policy can be considered. Since this decision has long-term legal implications, exceptions will be approved only by a member or members of Kefco 's senior management team.

The company specifically directs users not to destroy data in violation of this policy. Destroying data that a user may feel is harmful to himself or herself or destroying data in an attempt to cover up a violation of law or company policy is particularly forbidden.

4 RESPONSIBILITIES

Compliance, monitoring and review

The overall responsibility for ensuring compliance with the requirements of the related legislation in relation to performing all operational activities at Kefco rests with the Board of Directors.

All operating units’ staff that deal with personal data are responsible for processing this data in full compliance with the relevant Kefco policies and procedures.

Reporting in case of a data breach

In the case of possible data breach, the staff member(s) who first identifies the breach or incident, must immediately report all details of the incident to the Board of Directors.

The Board of Directors are required to report a personal data breach to the competent Data Protection Authority not later than 72 hours after becoming aware of it. The notification must include at least:

· a description of the nature of the breach, including, where possible, the categories and approximate number of data subjects and personal data records concerned;

· the name and contact details of the relevant person on the Board of Directors as a contact point;

· the likely consequences of the data breach; and

· measures taken or proposed by the controller to address the breach and/or mitigate its effects.

Where a personal data breach is likely to result in a high risk to the rights and freedoms of a data subject, the Board of Directors must communicate the breach to the data subject(s) without undue delay. The communication must describe in clear and plain language, the nature of the breach and at least:

· the name and contact details of the relevant person on the Board of Directors as a contact point;

· the likely consequences of the data breach; and

· measures taken or proposed by the controller to address the breach and/or mitigate its effects.

Records management

Staff must maintain all records relevant to administering this policy and procedure in electronic form in a recognised Kefco record keeping system.

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

5 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

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

· Data Backup: data copied to a second location, solely for the purpose of safe keeping of that data

· Data Encryption: the process of encoding data with an algorithm so that it is unintelligible and secure without the key. Used to protect data during transmission or while stored

· Data Encryption Key: an alphanumeric series of characters that enables data to be encrypted and decrypted

· 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

6 RELATED LEGISLATION AND DOCUMENTS

· Kefco Data Protection Policy

7 FOR MORE INFORMATION

You can contact our Data Protection Officers who are the Kefco Board of Directors by emailing: gdpr@kefco.uk

8 APPROVAL AND REVIEW DETAILS

Approval and Review	Details
Approval Authority	Board of Directors
Next Review Date	25/05/2019

Approval and Amendment History	Details
Original Approval Authority and Date	Board of Directors 25/05/2018
Amendment Authority and Date

DATA TRANSFERS POLICY

DEFINITION

Kefco and subsidiaries companies will hereafter be referred to as “Kefco”

1 PURPOSE

This policy and procedure establishes an effective, accountable and transparent framework for ensuring compliance with the requirements for data transfers by the GDPR.

2 SCOPE

This policy and procedure applies across all entities or subsidiaries owned, controlled, or operated by Kefco and to all employees, including part-time, temporary, or contract employees, that handle personal data and/or personal data transfers.

3 POLICY STATEMENT

The Kefco 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. The Kefco 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

TRANSFERS BETWEEN KEFCO SERVICES/ENTITIES

In order for Kefco to carry out its operations effectively across its various services/entities, there may be occasions when it is necessary to transfer personal data internally from one Entity to another, or to allow access to the personal data from an overseas location. Should this occur, the Kefco service/entity sending the personal data remains responsible for ensuring protection for that personal data.

Kefco handles the transfer of personal data between Kefco services/entities, where the location of the recipient entity is a third country, using the binding corporate rules transfer mechanism. Binding corporate rules provide legally binding, enforceable rights on data subjects with regard to the processing of their personal data and must be enforced by each approved Kefco service/entity, including their employees. Only transfer the minimum amount of personal data necessary for the particular purpose of the transfer (for example, to fulfil a transaction or carry out a particular service). Ensure adequate security measures are used to protect the personal data during the transfer (including password-protection and encryption, where necessary).

TRANSFERS TO THIRD PARTIES

Each Kefco service/entity will only transfer personal data to, or allow access by, third parties when it is assured that the information will be processed legitimately and protected appropriately by the recipient. Where third party processing takes place, each Kefco service/entity will first identify if, under applicable law, the third party is considered a data controller, or a data processor of the personal data being transferred.

Where the third party is deemed to be a data controller, the Kefco service/entity will enter into, in cooperation with the Board of Directors, an appropriate agreement with the controller to clarify each party’s responsibilities in respect to the personal data transferred. Where the third party is deemed to be a data processor, the Kefco service/entity will enter into, in cooperation with the Board of Directors, an adequate processing agreement with the data processor. The agreement must require the data processor to protect the personal data from further disclosure and to only process personal data in compliance with the Kefco instructions. In addition, the agreement will require the data processor to implement appropriate technical and organisational measures to protect the personal data as well as procedures for providing notification of personal data breaches.

RESPONSIBILITIES

Compliance, monitoring and review

The overall responsibility for ensuring compliance with the requirements of the related legislation in relation to performing data transfers activities at Kefco rests with the Board of Directors.

All operating units’ staff that deal with personal data are responsible for processing this data in full compliance with the relevant Kefco policies and procedures.

Records management

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

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

5 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.