“Just New Homes Ltd” has and maintains a data protection policy, which includes an organisational approach, is approved by the management, published and communicated as appropriate to all relevant persons. The policy conforms to and requires demonstration of compliance with the 6 principles specified in Article 5 of the GDPR in that it states personal data will be:
- Processed lawfully, fairly and in a transparent manner in relation to the data subject (“lawfulness, fairness and transparency”).
- Collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes; further processing of personal data for archiving purposes in the public interest, or scientific and historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered incompatible with the initial purposes; (“purpose limitation”).
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimisation”).
- Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (“accuracy”).
- 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 data will be processed solely for archiving purposes in the public interest, or scientific and historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required in order to safeguard the rights and freedoms of the data subject (“storage limitation”);
- Processed in a way that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (“integrity and confidentiality”).
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