Phone: +44 7384317833
Email: info@sendlibra.com
The Data Protection Act (DPA) regulates the 'processing' of 'personal data'. Its definition of 'personal data' covers all information relating to identifiable living individuals which is held on computer, in another 'automatically-processable' format or in a manual filing system which is structured so as to facilitate access to information relating to particular individuals. (Information relating to companies and other 'legal' persons is not caught). Its definition of 'processing' covers any conceivable activity in relation to personal data, including collection, analysis, processing in the ordinary sense of the word, storage, disclosure, international transfer and deletion.
On a day-to-day basis we have to process personal data in various circumstances and in relation to various categories of individual. This Policy deals specifically with personal data collected in the context of the establishment and management of our customer relationships and the execution of transactions on the instructions of our customers ('Customer and/or Transaction Management').
It is important to remember that the DPA regulates processing of personal data relating to all individuals, not just relating to customers. Information relating to individual representatives of corporate customers, or to individuals (or individual representatives of corporate entity) elsewhere in a payment chain – for example, an ultimate payee or an individual representative of a payment institutions - is also protected by the DPA.
The UK Information Commissioner (the 'Commissioner') is responsible for enforcement of the DPA and has published a range of guidance on data protection issues, all of which is available on the Commissioner's website at www.ico.gov.uk.
Fortune Portfolio's principal obligations under the DPA include:
***A copy of our Policy will be supplied to each employee***
The requirements set out in this Policy are mandatory unless otherwise stated and must be followed by all our employees. It is the responsibility of each such person to acquaint themselves with the requirements of this Policy.
Failure to comply with this Policy may constitute a serious disciplinary offence and could result in dismissal.
The company Nominated Officer (MLRO) is charged as the designated data protection officer (the 'Data Protection Officer').
Employees with any questions about our Data Protection Policy or application in particular circumstances should consult the Data Protection Officer.
The DPA requires that all of our processing of personal data should be fair and lawful and should meet one of various specified conditions. In designing and implementing each procedure for Customer and/or Transaction Management involving the processing of personal data, we will take these requirements into account and ensure that they are met.
Data subjects have statutory rights of access to and correction of the personal data that we hold about them. They also have a statutory right to object to our processing of their personal data, including their request to stop processing their data, although only in very limited circumstances. If a data subject attempts to exercise any of these statutory rights employees are required to immediately pass on this information by formal communication to the Data Protection Officer so that they can ensure that we respond appropriately and within the timescale laid down under the DPA. In recording and processing personal data for Customer and/or Transaction Management purposes employees should bear in mind data subjects' rights of access. Employees should not record personal data that employees would not want the data subject to see.