Introduction
Legend Ventures Limited, trading as Xocial is committed to being transparent about how it collects and uses the personal data of its external stakeholders, such as clients, suppliers, and business partners, and to meeting its data protection obligations. This policy applies to the personal data of all stakeholders and sets out the organisation’s commitment to data protection, and individual rights and obligations in relation to personal data.
Data Protection Officer
Legend Ventures Limited has appointed a Data Protection Officer (DPO). Their role is to inform and advise the organisation on its data protection obligations. They can be contacted at dpo@legendventures.co.uk. Questions about this policy, or requests for further information, should be directed to the Data Protection Officer.
DefinitionsPersonal data:
Any information that relates to a living individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing, or destroying it.
Special categories of personal data:
Information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, sexual orientation, and genetic and biometric data.
Criminal records data:
Information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.
Data Protection Principles
Legend Ventures Limited processes personal data in accordance with the following data protection principles:
Lawfulness, fairness, and transparency:
We process personal data lawfully, fairly, and in a transparent manner.
Purpose limitation:
We collect personal data only for specified, explicit, and legitimate purposes.
Data minimisation:
We process personal data only where it is adequate, relevant, and limited to what is necessary for the purposes of processing.
Accuracy:
We keep accurate personal data and take all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
Storage limitation:
We keep personal data only for the period necessary for processing.
Integrity and confidentiality:
We adopt appropriate measures to ensure that personal data is secure and protected against unauthorised or unlawful processing, and accidental loss, destruction, or damage.We inform individuals of the reasons for processing their personal data, how it uses such data, and the legal basis for processing in its privacy notices. We do not process personal data for other reasons. Where we rely on legitimate interests as the basis for processing data, we carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.When processing special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data. We will update personal data promptly if an individual advises that their information has changed or is inaccurate.Personal data gathered during the lifetime of contractual arrangements with our stakeholders is held in hard copy and electronic formats within Legend Ventures Limited's IT systems. The periods for which we hold personal data are contained in our privacy notices. We keep a record of our processing activities in respect of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).
Individual Rights
As a data subject, individuals have a number of rights in relation to their personal data.
Subject Access Requests
Individuals have the right to make a subject access request. If an individual makes a subject access request, we will inform them:Whether or not their data is processed and if so why, the categories of personal data concerned, and the source of the data if it is not collected from the individual;To whom their data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;For how long their personal data is stored (or how that period is decided);Their rights to rectification or erasure of data, or to restrict or object to processing;Their right to complain to the Information Commissioner if they think we have failed to comply with their data protection rights;Whether or not we carry out automated decision-making and the logic involved in any such decision-making.We will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless they agree otherwise. If the individual wants additional copies, we will charge a fee based on the administrative cost of providing the additional copies.To make a subject access request, the individual should send the request to dpo@legendventures.co.uk or complete a Subject Access Request Form available on our website. We have the right to ask for proof of identification before the request can be processed. The individual will need to verify their identity with the required documents.We will normally respond to a request within one month from the date it is received. In some cases, such as where we process large amounts of the individual’s data, we may respond within three months of the date the request is received. We will write to the individual within one month of receiving the original request to inform them if this is the case. If a subject access request is manifestly unfounded or excessive, we are not obliged to comply with it. Alternatively, we can agree to respond but will charge a fee based on the administrative cost of responding to the request. If an individual submits a request that is unfounded or excessive, we will notify them that this is the case and whether or not we will respond to it.
Other Rights
Individuals have a number of other rights in relation to their personal data. They can require us to:Rectify inaccurate data;Stop processing or erase data that is no longer necessary for the purposes of processing;Stop processing or erase data if the individual’s interests override our legitimate grounds for processing data (where we rely on legitimate interests as a reason for processing data);Stop processing or erase data if processing is unlawful;Stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override our legitimate grounds for processing data.To ask us to take any of these steps, the individual should send the request to dpo@legendventures.co.uk.
Data Security
We take the security of personal data seriously. We have internal policies and controls in place to protect personal data against loss, accidental destruction, misuse, or disclosure, and to ensure that data is not accessed except by employees in the proper performance of their duties. Access to our internal IT infrastructure is controlled by password protection to minimise the risk of illegal access from outside parties. All external third-party systems we use are password protected, and access is restricted in line with the role of the employee. All internal data is backed up daily and held externally by a third party on secure servers. Where we engage third parties to process personal data on our behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality, and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
Impact Assessments
Some processing activities may result in risks to privacy. Where processing would result in a high risk to individuals’ rights and freedoms, we will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This includes considering the purposes for which the activity is carried out, the risks for individuals, and the measures that can be put in place to mitigate those risks.
Data Breaches
If we discover that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, we will report it to the Information Commissioner within 72 hours of discovery. We will record all data breaches regardless of their effect. If the breach is likely to result in a high risk to the rights and freedoms of individuals, we will inform affected individuals about the breach and provide them with information about its likely consequences and the mitigation measures we have taken.
International Data Transfers
We will not transfer personal data to countries outside the EEA without ensuring adequate protection.
Individual Responsibilities
Individuals are responsible for helping us keep their personal data up to date. They should inform us if the data provided changes, such as a change in contact number or email address.Our employees may have access to the personal data of our external stakeholders in the course of their employment, contract, or volunteer period. Where this is the case, we rely on individuals to help meet our data protection obligations to all stakeholders.Individuals who have access to personal data are required to:Access only data that they have authority to access and only for authorised purposes;Not disclose data except to individuals (inside or outside the organisation) who have appropriate authorisation;Keep data secure (e.g., by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);Not remove personal data, or devices containing personal data, from our premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device;Not store personal data on local drives or on personal devices used for work purposes;Report data breaches to the Data Protection Officer immediately.
Training
We will provide training to all individuals about their data protection responsibilities as part of the induction process and at regular intervals thereafter. Information relating to GDPR, including fact sheets and guidance, will be regularly updated and stored within our systems. Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests, will receive additional training to help them understand their duties and how to comply with them.Thank you for trusting Legend Ventures Limited with your personal information. If you have any questions about this policy, please contact our Data Protection Officer at dpo@legendventures.co.uk.
