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Privacy policy

Data protection policy

1. Data protection principles

Kaleidoscope is committed to processing data in accordance with its responsibilities under
the GDPR.

Article 5 of the GDPR requires that personal data shall be:
“a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in
a manner that is incompatible with those purposes; further processing for archiving
purposes in the public interest, scientific or historical research purposes or
statistical purposes shall not be considered to be incompatible with the initial
purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for
which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be
taken to ensure that personal data that are inaccurate, having regard to the
purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is
necessary for the purposes for which the personal data are processed; personal
data may be stored for longer periods insofar as the personal data will be processed
solely for archiving purposes in the public interest, scientific or historical research
purposes or statistical purposes subject to implementation of the appropriate
technical and organisational measures required by the GDPR in order to safeguard
the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data,
including protection against unauthorised or unlawful processing and against
accidental loss, destruction or damage, using appropriate technical or
organisational measures.”

2. General provisions

a. This policy applies to all personal data processed by Kaleidoscope.
b. The Responsible Person shall take responsibility for Kaleidoscope’s ongoing
compliance with this policy.
c. This policy shall be reviewed at least annually.

3. Lawful, fair and transparent processing

a. To ensure its processing of data is lawful, fair and transparent, Kaleidoscope shall
maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests shall be dealt with in a timely manner.

4. Lawful purposes

a. All data processed by Kaleidoscope must be done on one of the following lawful bases:
consent, contract, legal obligation, vital interests, public task or legitimate interests
(see ICO guidance for more information).
b. Kaleidoscope shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of
opt-in consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option
for the individual to revoke their consent should be clearly available and systems
should be in place to ensure such revocation is reflected accurately in
Kaleidoscope’s systems.

5. Data minimisation

a. Kaleidoscope shall ensure that personal data are adequate, relevant and limited to
what is necessary in relation to the purposes for which they are processed.

6. Accuracy

a. Kaleidoscope shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put
in place to ensure that personal data is kept up to date.

7. Archiving / removal

a. To ensure that personal data is kept for no longer than necessary, Kaleidoscope
shall put in place an archiving policy for each area in which personal data is
processed and review this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long,
and why.

8. Security

a. Kaleidoscope shall ensure that personal data is stored securely using appropriate
software that is kept-up-to-date.
b. Access to personal data shall be limited to personnel who need access and
appropriate security should be in place to avoid unauthorised sharing of
information.
c. When personal data is deleted this should be done safely such that the data is
irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss,
alteration, unauthorised disclosure of, or access to, personal data, Kaleidoscope shall
promptly assess the risk to people’s rights and freedoms and if appropriate report this
breach to the ICO.