1.1 Background to the General Data Protection Regulation (‘GDPR’)
The General Data Protection Regulation 2016 replaces the EU Data Protection Directive of 1995 and supersedes the laws of individual Member States that were developed in compliance with the Data Protection Directive 95/46/EC. Its purpose is to protect the “rights and freedoms” of natural persons (i.e. living individuals) and to ensure that personal data is not processed in line with data protection principles and on a lawful basis.
This Data Protection Policy sets out Lumio Productions Ltd (hereafter referred to as “the company”) commitment to protecting the rights and privacy of individuals and details how we will ensure compliance with the GDPR and Irish data protection legislation.
The terms set out shall have the meanings set out opposite each of them.
“Automated Decision-Making (ADM)” – when a decision is made which is based solely on Automated Processing (including Profiling) which produces legal effects or significantly affects an individual. The GDPR prohibits Automated Decision-Making (unless certain conditions are met) but not Automated Processing.
“Automated Processing” – any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.
“child”– the GDPR defines a child for the purposes of providing information services as anyone under the age of 16 years old, although this may be lowered to 13 by Member State law. Where the Data Controller relies on Consent as the legal basis for processing under Article 6(1)(a) of the GDPR, the processing of Personal Data of a child in relation to information society services is only lawful if authorised by the holder of parental responsibility over the child. The Data Controller shall make reasonable efforts to verify in such cases that Consent is given or authorised by the holder of parental responsibility over the child.
“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.
“Data Controller” – the natural or legal person, public authority, agency or other body which, alone, or jointly with others, determines the purposes and means of the Processing of Personal Data where the purpose and means of such Processing are determined by European Union (“EU”) or Member State law, the Data Controller, or the specific criteria for its nomination is provided for by EU or Member State law.
“Data Processor” – the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller.
“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 Privacy by Default and should be conducted for all major system or business change programs involving the Processing of Personal Data.
“Data Protection Officer (DPO)” – the person required to be appointed in specific circumstances under the GDPR. Where a mandatory DPO has not been appointed, this term means a data protection manager or other voluntary appointment of a DPO or refers to the company’s data privacy team with responsibility for data protections compliance.
“Data Subject” – any living individual who is the subject of Personal Data held by the company.
“Explicit Consent” – Consent which requires a very clear and specific statement (that is, not just action).
“Member State” – any member state of the European Union.
“Lumio Personnel” – all employees, workers, contractors, consultants, directors, members and others.
“Personal Data” – any information relating to a 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 natural person.
“Personal Data Breach” – a breach of security leading to the accidental, or unlawful, destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed. There is an obligation on the Data Controller to report Personal Data breaches to the supervisory authority and where the breach is likely to adversely affect the Personal Data or privacy of the Data Subject.
“Privacy by Default” – implementing appropriate technical and organisational measures in an effective manner, as defaults into our Personal Data Processing activities to ensure compliance with the GDPR.
“Privacy by Design” implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the GDPR.
“Processing” – any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Special Categories of Personal Data” – Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
“third party” – a natural or legal person, public authority, agency or body other than the Data Subject, Data Controller, Data Processor and persons who, under the direct authority of the Data Controller or Data Processor, are authorised to process Personal Data.
2. POLICY STATEMENT AND SCOPE
2.1 The company recognises that the correct and lawful treatment of Personal Data will maintain confidence in the company 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.
2.2 Lumio Productions Ltd, located at Unit 246 Blanchardstown Corporate Park 2 Ballycoolin, Dublin 15, D15 F2XT is committed to compliance with all relevant EU and Member State laws in respect of Personal Data, and the protection of the “rights and freedoms” of individuals whose information the company collects and processes in accordance with the GDPR.
2.3 Compliance with the GDPR is described by this Policy along with connected processes and procedures.
2.4 The GDPR and this Policy apply to all of the company’s Personal Data processing functions, including those performed on its stakeholders’, employees’, and suppliers’ Personal Data, and any other Personal Data the company processes from any source.
2.5 The DPO is responsible for reviewing the register of processing regularly in the light of any changes to the company’s activities (as determined by changes to the data inventory register and the management review) and to any additional requirements identified by means of data protection impact assessments. This register needs to be available on the supervisory authority’s request.
2.6 This Policy applies to all Lumio Personnel. Any breach of the GDPR and/or any related policies will be dealt with under the company’s disciplinary policy and may also be a criminal offence, in which case the matter will be reported as soon as possible to the appropriate authorities.
2.7 Partners and any third parties working with or for the company, and who have or may have access to Personal Data, will be expected to have read, understood and to comply with this Policy. No third party may access Personal Data held by the company without having first entered into a data processing agreement, which imposes on the third party obligations no less onerous than those to which the company is committed, and which gives the company the right to audit compliance with the agreement.
2.8 Please contact the DPO with any questions about the operation of this Policy or the GDPR or if you have any concerns that this Policy is not being or has not been followed. In particular, you must always contact the DPO in the following circumstances:
2.8.1 if you are unsure of the lawful basis which you are relying on to process Personal Data;
2.8.2 if you need to rely on consent and/or need to capture Explicit Consent;
2.8.3 if you need to draft privacy notices or fair processing notices;
2.8.4 if you are unsure about the retention period for the Personal Data being processed;
2.8.5 if you are unsure about what security or other measures you need to implement to protect Personal Data;
2.8.6 if there has been a Personal Data Breach;
2.8.7 if you are unsure on what basis to transfer Personal Data outside the EEA;
2.8.8 if you need any assistance dealing with any rights invoked by a Data Subject;
2.8.9 whenever you are engaging in a significant new, or change in, processing activity which is likely to require a DPIA or plan to use Personal Data for purposes others than what it was collected for;
2.8.10 if you plan to undertake any activities involving Automated Processing including profiling or Automated Decision-Making;
2.8.11 if you need help complying with applicable law when carrying out direct marketing activities; or
2.8.12 if you need help with any contracts or other areas in relation to sharing Personal Data with third parties (including our vendors).
3. RESPONSIBILITIES AND ROLES UNDER THE GENERAL DATA PROTECTION REGULATION
3.1 The company is a data controller under the GDPR.
3.2 Top Management and all those in managerial or supervisory roles throughout the company are responsible for developing and encouraging good information handling practices within the company; responsibilities are set out in individual job descriptions.
3.3 The DPO is a role specified in the GDPR. The DPO shall report to the Chief Executive Officer for the management of Personal Data within the company and for ensuring that compliance with data protection legislation and good practice can be demonstrated.
3.4 The DPO, who, the company considers to be suitably qualified and experienced, has been appointed to take responsibility for the company’s compliance with this Policy on a day-to-day basis and has direct responsibility for ensuring that the company complies with the GDPR.
3.5 The DPO has specific responsibilities in respect of procedures such as the [Subject Access Request Procedure] and are the first point of call for Lumio Personnel seeking clarification on any aspect of data protection compliance.
3.6 Lumio Personnel are responsible for ensuring that any Personal Data about them and supplied by them to the company is accurate and up-to-date.
4. DATA PROTECTION PRINCIPLES
All processing of Personal Data must be conducted in accordance with the data protection principles as set out in Article 5 of the GDPR. The company’s policies and procedures are designed to ensure compliance with the principles.
4.1 Personal data must be processed lawfully, fairly and transparently
Lawful – identify a lawful basis before you can process Personal Data. These are often referred to as the “conditions for processing”, for example consent.
Fairly – in order for processing to be fair, the Data Controller has to make certain information available to the Data Subjects as practicable. This applies whether the Personal Data was obtained directly from the Data Subjects or from other sources.
The GDPR has increased requirements about what information should be available to Data Subjects, which is covered in the ‘Transparency’ requirement.
Transparency – the GDPR includes rules on giving privacy information to Data Subjects in Articles 12, 13 and 14. These are detailed and specific placing an emphasis on making privacy notices understandable and accessible. Information must be communicated to the Data Subject in an intelligible form using clear and plain language.
The specific information that must be provided to the Data Subject includes the identity of the Data Controller and DPO, how and why we will use, process, disclose, protect and retain that Personal Data as well as providing details on how Data Subjects may exercise their rights.
4.2 Personal Data can only be collected for specific, explicit and legitimate purposes
Data obtained for specified purposes must not be used for other purposes, save where the GDPR provides for same.
4.3 Personal Data must be adequate, relevant and limited to what is necessary for processing
4.3.1 The company must not collect information that is not strictly necessary for the purpose for which it is obtained.
4.3.2 All data collection forms (electronic or paper-based), including data collection requirements in new information systems, must be include a fair processing statement or link to privacy statement and approved by the DPO.
4.3.3 The DPO will ensure that, on a regular basis all data collection methods are reviewed to ensure that collected data continues to be adequate, relevant and not excessive.
4.4 Personal Data must be accurate and kept up to date with every effort to erase or rectify without delay
4.4.1 Personal Data that is stored by the Data Controller must be reviewed and updated as necessary. No data should be kept unless it is reasonable to assume that it is accurate.
4.4.2 The DPO, supported and resourced by the company is responsible for ensuring that all staff are trained in the importance of collecting accurate data and maintaining it.
4.4.3 It is also the responsibility of the Data Subject to ensure that data held by the company is accurate and up to date. Completion of a registration or application form by a Data Subject will include a statement that the data contained therein is accurate at the date of submission.
4.4.4 Lumio Personnel should be required to notify the company of any changes in circumstance to enable personal records to be updated accordingly. Instructions for updating records will be made available to staff. It is the responsibility of the company to ensure that any notification regarding a change of circumstances is recorded and acted upon.
4.5 Personal Data must be kept in a form such that the Data Subject can be identified only as long as is necessary for processing.
4.5.1 Personal Data will be retained until completion of the event and, once its retention date is passed, it must be securely destroyed.
4.6 Personal Data must be processed in a manner that ensures the appropriate security
4.6.1 The DPO, supported and resourced by the company, will carry out a risk assessment taking into account all the circumstances of the company’s controlling or processing operations.
4.6.2 In determining appropriateness, the DPO should also consider the extent of possible damage or loss that might be caused to individuals (e.g. staff or stakeholders) if a security breach occurs, the effect of any security breach on the company itself, and any likely reputational damage including the possible loss of customer trust.
4.6.3 The security measures which the company have in place are set out in section 8 of this Policy. These controls have been selected on the basis of identified risks to Personal Data, and the potential for damage or distress to individuals whose data is being processed.
4.7 The controller must be able to demonstrate compliance with the GDPR’s other principles (accountability)
4.7.1 The GDPR includes provisions that promote accountability and governance. These complement the GDPR’s transparency requirements. The accountability principle in Article 5(2) requires you to demonstrate that you comply with the principles and states explicitly that this is your responsibility.
4.7.2 The company will demonstrate compliance with the data protection principles by implementing data protection policies, adhering to codes of conduct, implementing technical and organisational measures, as well as adopting techniques such as data protection by design and by default, DPIAs, breach notification procedures and incident response plans.
4.7.3 The company must have adequate resources and controls in place to ensure and to document GDPR compliance including:
(a) appointing a suitably qualified DPO (where necessary) and an executive accountable for data privacy;
(b) implementing Privacy by Design and Privacy by Default when Processing Personal Data and completing DPIAs where Processing presents a high risk to rights and freedoms of Data Subjects;
(c) integrating data protection into internal documents including this Policy and/or any related policies;
(d) regularly training Lumio Personnel on the GDPR, this Policy, and/or any related policies and data protection matters including, for example, Data Subject’s rights, Consent, legal basis, DPIA and Personal Data Breaches. The company must maintain a record of training attendance by Lumio Personnel; and
(e) regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort.
4.7.4 Record Keeping
(a) The GDPR requires the company to keep full and accurate records of all our data processing activities.
(b) The company is required to keep and maintain accurate corporate records reflecting its processing including records of Data Subjects’ Consents and procedures for obtaining Consents.
(c) These records should include, at a minimum, the name and contact details of the Data Controller and the DPO, 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. In order to create such records, data maps should be created which should include the detail set out above together with appropriate data flows.
4.7.5 Training and Audit
(a) The company is required to ensure all Lumio staff have undergone adequate training to enable them to comply with data privacy laws. The company will also regularly test its systems and processes to assess compliance.
(b) The company undertakes to provide employees with privacy related training. Attendance will be mandatory.
(c) The company is required to regularly review all the systems and processes under its control to ensure they comply with this Policy and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.
4.7.6 Privacy by Design, Privacy by Default and Data Protection Impact Assessment (DPIA)
The company is required to implement Privacy by Design and Privacy by Default 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. The company must assess what Privacy by Design and Privacy by Default measures can be implemented on all programs/systems/processes that process Personal Data by taking into account the following:
(a) the state of the art;
(b) the cost of implementation;
(c) the nature, scope, context and purposes of processing; and
(d) the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the processing.
4.7.7 Data Controllers must also conduct DPIAs in respect to high risk processing.
(a) use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes);
(b) Automated Processing including profiling and ADM;
(c) large scale processing of Special Categories of Personal Data; and
(d) large scale, systematic monitoring of a publicly accessible area.
4.7.8 A DPIA must include:
(a) a description of the processing, its purposes and the Data Controller’s legitimate interests if appropriate;
(b) an assessment of the necessity and proportionality of the processing in relation to its purpose;
(c) an assessment of the risk to individuals; and
(d) the risk mitigation measures in place and demonstration of compliance.
4.7.9 Automated Processing (including profiling) and Automated Decision-Making (ADM)
Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:
(a) a Data Subject has Explicitly Consented;
(b) the Processing is authorised by law; or
(c) the Processing is necessary for the performance of or entering into a contract.
4.7.10 If certain types of Special Categories of Personal Data are being processed, then grounds (b) or (c) will not be allowed but such Special Categories of Personal Data can be processed where it is necessary (unless less intrusive means can be used) for substantial public interest like fraud prevention.
4.7.12 The company must also inform the Data Subject of the logic involved in the decision making or profiling, the significance and envisaged consequences and give the Data Subject the right to request human intervention, express their point of view or challenge the decision.
4.7.13 A DPIA must be carried out before any Automated Processing (including profiling) or ADM activities are undertaken.
4.7.14 Sharing Personal Data
(a) Generally the company will not share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.
(b) Personal Data may only be shared with another employee or contractor if the recipient has a job related need to know the information and the transfer complies with any applicable cross- border transfer restrictions.
4.7.15 Personal Data held by the company may only be shared with third parties, such as our service providers if:
(a) they have a need to know the information for the purposes of providing the contracted services;
(b) sharing the Personal Data complies with the information notice provided to the Data Subject and, if required, the Data Subject’s Consent has been obtained;
(c) the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
(d) the transfer complies with any applicable cross border transfer restrictions; and
(e) a fully executed written contract that contains GDPR approved third party clauses has been obtained.
5.1 In general, the company does not rely on Consent as a legal basis for processing Personal Data however there are limited circumstances in which the compnay will rely on Consent.
5.2 The compnay understands ‘consent’ to mean that the Data Subject has been fully informed of the intended processing and has signified their agreement, while in a fit state of mind to do so and without pressure being exerted upon them. Consent obtained under duress or on the basis of misleading information will not be a valid basis for processing. The Data Subject can withdraw their Consent at any time.
5.3 There must be some active communication between the parties to demonstrate active Consent. Consent cannot be inferred from non-response to a communication. The Controller must be able to demonstrate that Consent was obtained for the processing operation.
5.4 For Special Categories of Personal Data, Explicit Consent of Data Subjects must be obtained unless an alternative legitimate basis for processing exists.
5.5 Where the company provides online services to children, parental or custodial authorisation must be obtained. This requirement applies to children under the age of 16 (unless the Member State has made provision for a lower age limit, which may be no lower than 13).
6. FREEDOM OF INFORMATION
6.1 In order to comply with the Freedom of Information Act 2014 (“FOI”), the company has to routinely publish information whenever possible and make information held available to citizens. The company maintains a separate FOI policy which can be found on its website.
7. DATA SUBJECTS’ RIGHTS
7.1 Data Subjects have the following rights regarding data processing, and the data that is recorded about them:
7.1.1 To make subject access requests regarding the nature of information held and to whom it has been disclosed.
7.1.2 To prevent processing likely to cause damage or distress.
7.1.3 To prevent processing for purposes of direct marketing.
7.1.4 To be informed about the mechanics of automated decision-taking process that will significantly affect them.
7.1.5 To not have significant decisions that will affect them taken solely by automated process.
7.1.6 To sue for compensation if they suffer damage by any contravention of the GDPR.
7.1.7 To take action to rectify, block, erase, including the right to be forgotten, or destroy inaccurate personal data.
7.1.8 To request the supervisory authority to assess whether any provision of the GDPR has been contravened.
7.1.9 To have Personal Data provided to them in a structured, commonly used and machine-readable format, and the right to have that data transmitted to another controller.
7.1.10 To object to any automated profiling that is occurring without Consent
7.1.11 To withdraw Consent to processing at any time.
7.1.12 To restrict processing in specific circumstances.
7.1.13 To challenge processing which has been justified on the basis of legitimate interests or in the public interest.
7.1.14 To request a copy of an agreement under which Personal Data is transferred outside of the EEA.
7.1.15 To be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms.
7.2 The company ensures that Data Subjects may exercise these rights:
7.2.1 Data Subjects may make data access requests as described in the company’s [Subject Access Request Procedure]; this procedure also describes how the company will ensure that its response to the data access request complies with the requirements of the GDPR.
7.2.2 Data Subjects have the right to complain to the company related to the processing of their Personal Data, the handling of a request from a Data Subject and appeals from a Data Subject on how complaints have been handled in line with the company’s [Complaints Procedure].
8. SECURITY OF DATA AND PERSONAL DATA BREACHES
8.1 All Lumio Personnel are responsible for ensuring that any Personal Data that the company holds and for which the company is responsible, is kept securely and is not under any conditions disclosed to any third party unless that third party has been specifically authorised by the company to receive that information and has entered into a confidentiality agreement.
8.2 All Personal Data should be accessible only to those who need to use it, and access may only be granted in line with the company’s [Access Control Policy]. All Personal Data should be treated with the highest security and must be kept:
- in a lockable room with controlled access; and/or
- in a locked drawer or filing cabinet; and/or
- if computerised, password protected in line with corporate requirements in Lumio’s [Access Control Policy]; and/or
- stored on (removable) computer media which are encrypted in line with [Secure Disposal of Storage Media].
8.3 Care must be taken to ensure that PC screens and terminals are not visible except to authorised Lumio Personnel. All Lumio Personnel are required to enter into an [Acceptable Use Agreement] before they are given access to organisational information of any sort, which details rules on screen time-outs.
8.4 Manual records may not be left where they can be accessed by unauthorised personnel and may not be removed from business premises without authorisation. As soon as manual records are no longer required for day-to-day client support, they must be removed for secure archiving in line with the company’s [Archiving Policy].
8.5 Personal Data may only be deleted or disposed of in line with [the Personal Data Retention and Disposal Policy]. Manual records that have reached their retention date are to be shredded and disposed of as ‘confidential waste’. Hard drives of redundant PCs are to be removed and immediately destroyed as per the [Personal Data Retention and Disposal Policy ].
8.6 Processing of Personal Data ‘off-site’ presents a potentially greater risk of loss, theft or damage to Personal Data. Staff must be specifically authorised to process data off-site.
8.7 The GDPR requires Data Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data Subject.
8.8 The company has put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where the company is legally required to do so.
8.9 If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the person or team designated as the key point of contact for Personal Data Breaches, the DPO, the information technology or security department, the legal department and follow the [Personal Data Breach Policy and Procedures]. You should preserve all evidence relating to the potential Personal Data Breach.
9. DISCLOSURE OF DATA
9.1 The company must ensure that Personal Data is not disclosed to unauthorised third parties which includes family members, friends, government bodies, and in certain circumstances, relevant law enforcement bodies. All Lumio Personnel should exercise caution when asked to disclose Personal Data held on another individual to a third party. It is important to bear in mind whether or not disclosure of the information is relevant to, and necessary for, the conduct of the company’s business.
9.2 All requests to provide data for one of these reasons must be supported by appropriate paperwork and all such disclosures must be specifically authorised by the DPO.
10. RETENTION AND DISPOSAL OF DATA
10.1 The company shall not keep Personal Data in a form that permits identification of Data Subjects for longer a period than is necessary, in relation to the purpose(s) for which the data was originally collected
10.2 The retention period for each category of Personal Data shall be no longer than 24 hours past event completion.
10.3 Personal Data must be disposed of securely in accordance with the sixth principle of the GDPR – processed in an appropriate manner to maintain security, thereby protecting the “rights and freedoms” of Data Subjects.
11. DATA TRANSFERS
11.1 The company does not transfer Personal Data out of the European Economic Area.
11.2 This section of the policy will be revised accordingly if the company proposes to transfer Personal Data outside of the European Economic Area.
12. INFORMATION ASSET REGISTER/DATA INVENTORY
12.1 The company has established a data inventory and data flow process as part of its approach to address risks and opportunities throughout its GDPR compliance project. The company’s data inventory and data flow determines:
- business processes that use Personal Data;
- source of Personal Data;
- volume of Data Subjects;
- description of each item of Personal Data;
- processing activity;
- maintains the inventory of data categories of Personal Data processed;
- documents the purpose(s) for which each category of Personal Data is used;
- recipients, and potential recipients, of the Personal Data;
- the role of the company throughout the data flow;
- key systems and repositories;
- any data transfers; and
- all retention and disposal requirements.
12.2 The company is aware of any risks associated with the processing of particular types of Personal Data.
12.2.1 The company assesses the level of risk to individuals associated with the processing of their Personal Data. Data protection impact assessments (DPIAs) are carried out in relation to the processing of Personal Data by the company, and in relation to processing undertaken by other organisations on behalf of the company.
12.2.2 The company shall manage any risks identified by the risk assessment in order to reduce the likelihood of a non-conformance with this Policy.
12.2.3 Where a type of processing, in particular using new technologies and taking into account the nature, scope, context and purposes of the processing is likely to result in a high risk to the rights and freedoms of natural persons, the company shall, prior to the processing, carry out a DPIA of the impact of the envisaged processing operations on the protection of Personal Data. A single DPIA may address a set of similar processing operations that present similar high risks.
12.2.4 Where, as a result of a DPIA it is clear that the company is about to commence processing of Personal Data that could cause damage and/or distress to the Data Subjects, the decision as to whether or not the company may proceed must be escalated for review to the DPO.
12.2.5 The DPO shall, if there are significant concerns, either as to the potential damage or distress, or the quantity of data concerned, escalate the matter to the supervisory authority.
12.2.6 Appropriate controls will be put in place and applied to reduce the level of risk associated with processing individual data to an acceptable level to meet the requirements of the GDPR.
13. DOCUMENT OWNER AND APPROVAL
13.1 The DPO is the owner of this document and is responsible for ensuring that this Policy document is reviewed in line with the review requirements stated above and in consultation with senior management of the company and the DPO.