GDPR Data Protection Policy

BNM Analytics Limited.

Introduction

BNM Analytics Limited is committed to conducting its business in accordance with all applicable Data Protection laws and regulations and in line with the highest standards of ethical conduct.

This policy details expected behaviours of BNM Analytics Limited Employees and Third Parties in relation to the collection, use, retention, transfer, disclosure and destruction of any Personal Data belonging to a BNM Analytics Limited’ Customers and Staff (i.e. the Data Subject) and irrespective of the media used to store the information.

Personal Data is any information (including opinions and intentions) which relates to an identified or Identifiable Natural Person. Personal Data is subject to certain legal safeguards and other regulations, which impose restrictions on how organisations may process Personal Data.

An organisation that handles personal data and makes decisions about its use is known as a Data Controller. BNM Analytics Limited’, as a Data Controller, is responsible for ensuring compliance with the Data Protection requirements outlined in this policy.

Non-compliance may expose BNM Analytics Limited to complaints, regulatory action, fines and/or reputational damage.

BNM Analytics Limited leadership team is fully committed to ensuring continued and effective implementation of this policy and expects all BNM Analytics Limited Employees, Volunteers and Third Parties to share in this commitment.

Any breach of this policy will be taken seriously and may result in disciplinary action or business sanction.

Scope

1.1. This policy applies to all BNM Analytics Limited Entities where a Data Subject’s personal data is processed:
- in the context of the business activities of BNM Analytics Limited Entity
- for the provision or offer of goods or services to individuals (including those provided or

offered free-of-charge) by BNM Analytics Limited

- to actively monitor the behaviour of individuals.
1.2. Monitoring the behaviour of individuals includes using data processing techniques such as persistent web browser cookies or dynamic IP address tracking to profile an individual with a view to:
- taking a decision about them
- analysing or predicting their personal preferences, behaviours and attitudes.
1.3. This policy applies to all processing of personal data in electronic form (including electronic mail and documents created with word processing software) or where it is held in manual files that are structured in a way that allows ready access to information about individuals.
1.4. This policy has been designed to establish a baseline standard for the processing and protection of personal data by all BNM Analytics Limited Employees. Where national law imposes a requirement that is stricter than that imposed by this policy, the requirements in national law must be followed. Furthermore, where national law imposes a requirement that is not addressed in this policy, the relevant national law must be adhered to.
1.5. The protection of personal data belonging to BNM Analytics Limited Employees is not within the scope of this policy.
1.6. The DPO is responsible for overseeing this Privacy Standard and, as applicable, developing Related Policies and Privacy Guidelines.
1.7. Please contact the DPO with any questions about the operation of this Privacy Standard or the GDPR, or if you have any concerns that this Privacy Standard is not being or has not been followed. In particular, you must always contact the DPO in the following circumstances:
- if you are unsure of the lawful basis which you are relying on to process Personal Data
- if you need to rely on Consent and/or need to capture Explicit Consent
- if you need to draft Privacy Notices or Fair Processing Notices
- if you are unsure about the retention period for the Personal Data being Processed
- if you are unsure about what security or other measures you need to implement to protect Personal Data
- if there has been a Personal Data Breach
- if you are unsure on what basis to transfer Personal Data outside the EEA
- if you need any assistance dealing with any rights invoked by a Data Subject
- 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

- if you plan to undertake any activities involving Automated Processing including profiling or

Automated Decision-Making

- if you need help complying with applicable law when carrying out direct marketing activities;

- if you need help with any contracts or other areas in relation to sharing Personal Data with

Third Parties (including our vendors).

Definitions

TERM

ANONYMISATION

DEFINITION

Data amended in such a way that no individuals can be identified from the data (whether directly or indirectly) by any means or by any person.

Any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.

A 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.

The process of safeguarding Personal Data from unauthorised or unlawful disclosure, access, alteration, Processing, transfer or destruction.

Anyone 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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

BINDING CORPORATE RULES The Personal Data protection policies used for the transfer of Personal Data to one or more Third Countries within a group of undertakings, or group of

enterprises engaged in a joint economic activity.

CONSENT

CUSTOMER Any past, current or prospective BNM Analytics Limited customer.

DATA CONTROLLER

DATA PROCESSOR A natural or legal person, Public Authority, Agency or other body which Processes Personal Data on behalf of a Data Controller.

DATA PROTECTION

DATA PROTECTION OFFICER The person required to be appointed in specific circumstances under the GDPR. (DPO) Where a mandatory DPO has not been appointed, this term means a data

protection manager or other voluntary appointments of a DPO or refers to the Company data privacy team with responsibility for data protection compliance.

DATA SUBJECT

EEA The 28 countries in the EU, and Iceland, Liechtenstein and Norway.

EMPLOYEE

An individual who works part-time or full-time for BNM Analytics Limited under a contract of employment, whether oral or written, express or implied, and has recognised rights and duties – includes temporary employees and independent contractors.

An independent Public Authority in the UK responsible for monitoring the application of the relevant Data Protection regulation set forth in national law.

Any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means. Operations performed may include 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.

Data amended in such a way that no individuals can be identified from the data (whether directly or indirectly) without a ‘key’ that allows the data to be re- identified.

ENCRYPTION The process of encoding a message or information in such a way that only authorised parties can access it.

INFORMATION COMMISSIONER’S OFFICE (ICO)

PROCESS, PROCESSED, PROCESSING

PSEUDONYMISATION

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.

PROFILING Any form of automated processing of Personal Data, where Personal Data is used to evaluate specific or general characteristics relating to a data subject. In

particular to analyse or predict certain aspects concerning that natural person’s performance at work, economic situations, health, personal preferences, interests, reliability, behaviour, location or movement.

SPECIAL CATEGORIES OF DATA Personal Data pertaining to or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, data

concerning health or sex life and sexual orientation, genetic data or biometric data.

Policy

3.1. Governance

3.1.1. Policy Dissemination and Enforcement

The management team of BNM Analytics Limited must ensure that all BNM Analytics Limited Employees responsible for the Processing of Personal Data are aware of and comply with the contents of this policy. In addition, BNM Analytics Limited will make sure all Third Parties engaged to Process Personal Data on their behalf (i.e. their Data Processors) are aware of and comply with the contents of this policy. Assurance of such compliance must be obtained from all Third Parties, whether companies or individuals, prior to granting them access to Personal Data controlled by BNM Analytics Limited

3.1.2. Data Protection by Design

To ensure that all Data Protection requirements are identified and addressed when designing new systems or processes and/or when reviewing or expanding existing systems or processes, each of them must go through an approval process before continuing.

BNM Analytics Limited must ensure that a Data Protection Impact Assessment (DPIA) is conducted, for all new and/or revised systems or processes for which it has responsibility. BNM Analytics Limited should consult with a Data Protection subject matter expert during the course of completing the DPIA. The subsequent findings of the DPIA must then be submitted to the senior risk office for BNM Analytics Limited for review and approval. Where applicable, the Information Technology (IT) department, as part of its IT system and application design review process, will cooperate with the Data Protection subject matter expert to assess the impact of any new technology uses on the security of Personal Data.

3.1.3. Compliance Monitoring

To confirm that an adequate level of compliance is being achieved by BNM Analytics Limited in relation to this policy, BNM Analytics Limited will carry out an annual Data Protection compliance audit. Each audit will, as a minimum, assess compliance with this policy and the operational practices in relation to the protection of Personal Data, including:

the assignment of responsibilities
• raising awareness
• training of Employees
• adequacy of organisational and technical controls to protect Personal Data • records management procedures (including data minimisation)
adherence to the qualified rights of the Data Subject • Privacy by Design and Default
• consent for direct marketing
• Personal Data transfers
Personal Data incident management (including Personal Data breaches) • Personal Data complaints handling
• the currency of Data Protection policies and Privacy Notices
• the accuracy of Personal Data being stored
the conformity of Data Processor activities
• the adequacy of procedures for redressing poor compliance.

Any major deficiencies identified will be reported to and monitored by BNM Analytics Limited Management Team.

3.2. Principles
3.2.1. Data Protection

BNM Analytics Limited has adopted the following principles to govern its collection, use, retention, transfer, disclosure and destruction of Personal Data.

PRINCIPLE

PRINCIPLE 1: Lawfulness, Fairness and Transparency

PRINCIPLE 3: Data Minimisation

PRINCIPLE 5: Storage Limitation

DEFINITION

Personal Data shall be processed lawfully, fairly and in a transparent manner in relation to the Data Subject. This means, BNM Analytics Limited must tell the Data Subject what Processing will occur (transparency), the Processing must match the description given to the Data Subject (fairness), and it must be for one of the purposes specified in the applicable Data Protection regulation (lawfulness).

Personal Data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are Processed. This means BNM Analytics Limited must not store any Personal Data beyond what is strictly required.

Personal Data shall be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data is Processed. This means BNM Analytics Limited must, wherever possible, store Personal Data in a way that limits or prevents identification of the Data Subject.

PRINCIPLE 2: Purpose Limitation

PRINCIPLE 4: Accuracy

Personal Data shall be collected for specified, explicit and legitimate purposes and not further Processed in a manner that is incompatible with those purposes. This means BNM Analytics Limited must specify exactly what the Personal Data collected will be used for and limit the Processing of that Personal Data to only what is necessary to meet the specified purpose.

Personal Data shall be accurate and kept up to date. This means BNM Analytics Limited must have in place processes for identifying and addressing out-of-date, incorrect and redundant Personal Data.

PRINCIPLE 6: Integrity & Confidentiality

Personal Data shall be 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. BNM Analytics Limited must use appropriate technical and organisational measures to ensure the integrity and confidentiality of Personal Data are maintained at all times.

3.2.2. Accountability

The Data Controller shall be responsible for, and be able to demonstrate, compliance. This means BNM Analytics Limited must demonstrate that the six Data Protection Principles (outlined above) are met for all Personal Data for which it is responsible.

3.3. Data Collection

Personal Data should be collected only from the Data Subject unless one of the following applies:

The nature of the business purpose necessitates collection of the Personal Data from other

persons or bodies.

The collection must be carried out under emergency circumstances in order to protect the

vital interests of the Data Subject or to prevent serious loss or injury to another person.

If Personal Data is collected from someone other than the Data Subject, the Data Subject

must be informed of the collection unless one of the following apply:

theDataSubjecthasreceivedtherequiredinformationbyothermeans
the information must remain confidential due to a professional secrecy obligation
a national law expressly provides for the collection, Processing or transfer of the Personal Data.

Where it has been determined that notification to a Data Subject is required, notification should occur promptly, but in no case later than:

one calendar month from the first collection or recording of the Personal Data
at the time of first communication, if used for communication with the Data Subject
at the time of disclosure, if disclosed to another recipient.

3.3.1. Data Subject Consent

BNM Analytics Limited will obtain Personal Data only by lawful and fair means and, where appropriate, with the knowledge and Consent of the individual concerned.

Where a need exists to request and receive the Consent, via an agreement or positive action, from an individual prior to the collection, use or disclosure of their Personal Data, BNM Analytics Limited is committed to seeking such Consent.

BNM Analytics Limited shall establish a system for obtaining and documenting Data Subject consent for the collection, processing, and/or transfer of their personal data. The system must include provisions for:

determining what disclosures should be made in order to obtain valid Consent
• ensuring the request for Consent is presented in a manner which is clearly distinguishable

from any other matters, is made in an intelligible and easily accessible form, and uses clear

and plain language
• ensuring the Consent is freely given (i.e. is not based on a contract that is conditional to the

processing of Personal Data that is unnecessary for the performance of that contract)
• documenting the date, method and content of the disclosures made, as well as the validity,

scope, and volition of the Consents given
• providing a simple method for a Data Subject to withdraw their Consent at any time.

3.3.2. External Privacy Notes

Each external website provided by BNM Analytics Limited will include an online ‘Privacy Notice’ and an online ‘Cookie Notice’ fulfilling the requirements of applicable law.

3.4. Data Use
3.4.1. Data Processing

BNM Analytics Limited uses the Personal Data of its Customers for the following broad purposes: • the general running and business administration of BNM Analytics Limited
• to provide goods or services to BNM Analytics Limited customers.
• the ongoing administration and management of customer services.

The use of a Customer’s information should always be considered from their perspective and whether the use will be within their expectations or if they are likely to object. For example, it would clearly be within a Customer’s expectations that their details will be used by BNM Analytics Limited to respond to a Customer’s request for information about the products and services on offer. However, it will not be within their reasonable expectations that BNM Analytics Limited would then provide their details to Third Parties for marketing purposes.

BNM Analytics Limited will Process Personal Data in accordance with all applicable laws and applicable contractual obligations. More specifically, BNM Analytics Limited will not Process Personal Data unless at least one of the following requirements are met:

The Data Subject has given Consent to the Processing of their Personal Data for one or more specific purposes.
Processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract.
Processing is necessary for compliance with a legal obligation to which the Data Controller is subject.
Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person.

Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.
Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a Third Party (except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject, in particular where the Data Subject is a child).

There are some circumstances in which Personal Data may be further processed for purposes that go beyond the original purpose for which the Personal Data was collected.

3.4.2. Special Categories of Data

Special categories or data (also known as sensitive data) include the following: • racial or ethnic origin
• political opinions
• religious or philosophical beliefs

trade union membership
• data concerning sex life, sexual orientation or health
• genetic data
• biometric data, where processed in a manner that will uniquely identify a person.

BNM Analytics Limited will only Process Special Categories of Data where the Data Subject expressly Consents to such Processing or where one of the following conditions apply:

The Processing relates to Personal Data which has already been made public by the Data Subject.
The Processing is necessary for the establishment, exercise or defence of legal claims.
The Processing is specifically authorised or required by law.
The Processing is necessary to protect the vital interests of the Data Subject or of another

natural person where the Data Subject is physically or legally incapable of giving Consent.

Further conditions, including limitations, based upon national law related to the Processing

of genetic data, biometric data or data concerning health.

Where Special Categories of Data are being Processed, BNM Analytics Limited will adopt additional protection measures.

3.4.3. Data Quality

BNM Analytics Limited will adopt all necessary measures to ensure that the Personal Data it collects and Processes is complete and accurate in the first instance and is updated to reflect the current situation of the Data Subject.

The measures adopted by BNM Analytics Limited to ensure data quality include:

correcting Personal Data known to be incorrect, inaccurate, incomplete, ambiguous,

misleading or outdated, even if the Data Subject does not request rectification

keeping Personal Data only for the period necessary, to satisfy the permitted uses or

applicable statutory retention period

the removal of Personal Data if in violation of any of the Data Protection principles or if the

Personal Data is no longer required

restriction, rather than deletion of Personal Data, insofar as:

o a law prohibits erasure
o erasure would impair legitimate interests of the data subject
o the Data Subject disputes that their Personal Data is correct and that it cannot be

clearly ascertained whether their information is correct or incorrect.

3.4.4. Profiling and Automated Decision-Making

BNM Analytics Limited will only engage in Profiling and automated decision-making where it is necessary to enter into, or to perform, a contract with the Data Subject or where it is authorised by law.

Where BNM Analytics Limited utilises Profiling and automated decision-making, this will be disclosed to the relevant Data Subjects. In such cases, the Data Subject will be given the opportunity to:

obtain an explanation for the automated decision
• review the logic used by the automated system
• supplement the automated system with additional data
• have a human carry out a review of the automated decision • contest the automated decision
• object to the automated decision-making being carried out.

BNM Analytics Limited must also ensure that all Profiling and automated decision-making relating to a Data Subject is based on accurate data. Appropriate mathematical or statistical profiling procedures must be in place, and the Data Controller must ensure suitable technical and organisational measures are undertaken to minimise the risk of errors.

3.4.5. Direct Marketing

As a general rule, BNM Analytics Limited will not send promotional or direct marketing material to a BNM Analytics Limited Customers through digital channels such as mobile phones, email and the Internet, without first obtaining their Consent.

The GDPR and Privacy and Electronic Communications (which governs Direct Marketing Activities within the EU) imports the GDPR standard for consent. That is:

The consent must be freely given, specific, informed and unambiguous.
• The consent must be expressed by a statement or clear affirmative action. Silence, pre-ticked

boxes or inactivity should therefore not constitute consent.
• The consent must be as easy to withdraw as it was to provide consent in the first place. • The organisation must be able to demonstrate that the individual has consented.
• The consent language must be intelligible and use clear and plain language.

Contacting recipients via email to establish whether consent is in place also constitutes direct marketing and is prohibited without first obtaining consent from the Customer.

The request for consent must be clearly distinguished from other matters. New marketing rules will apply equally to B2B and B2C marketing. Prior consent, before sending commercial electronic communications for direct marketing purposes will be required. This would mean if BNM Analytics Limited were proposing to email prospective or existing customers the Company would have to obtain prior opt-in/subscribe consent from individual members.

Where Personal Data Processing is approved for digital marketing purposes, the Data Subject must be informed at the point of first contact that they have the right to object, at any stage, to having their data Processed for such purposes. If the Data Subject puts forward an objection, digital marketing related Processing of their Personal Data must cease immediately, and their details should be kept on a suppression list with a record of the opt-out decision, rather than being completely deleted.

It should be noted that where digital marketing is carried out in a ‘business to business’ context, there is no legal requirement to obtain an indication of Consent to carry out digital marketing to individuals, provided that they are given the opportunity to opt-out.

A soft opt-in also remains for the use of e-mail contact details within the context of an existing customer relationship where BNM Analytics Limited has obtained personal details during the course of a previous sale or transaction.

3.5. Data Retention

To ensure fair Processing, Personal Data will not be retained by BNM Analytics Limited for longer than necessary in relation to the purposes for which it was originally collected, or for which it was further Processed.

The length of time for which BNM Analytics Limited needs to retain Personal Data is set out in BNM Analytics Limited Data Retention Schedule. This considers the legal and contractual requirements, both minimum and maximum, that influence the retention periods set forth in the schedule. All Personal Data should be securely deleted or destroyed as soon as possible where it has been confirmed that there is no longer a need to retain it.

3.6. Data Protection

3.6.1. BNM Analytics Limited will adopt physical, technical, and organisational measures to ensure the security and protect the confidentiality, integrity and availability of the Personal Data, defined as follows:

Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it.
Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed.
Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes

This includes the prevention of loss or damage, unauthorised alteration, access or Processing, and other risks to which it may be exposed by virtue of human action or the physical or natural environment.

3.6.2. A summary of the Personal Data related security measures is provided below:

Prevent unauthorised persons from gaining access to data processing systems in which

Personal Data are Processed.

Prevent persons entitled to use a data processing system from accessing Personal Data

beyond their needs and authorisations.

Ensure that Personal Data in the course of electronic transmission during transport

cannot be read or copied.

Ensure that access logs are in place to establish whether, and by whom, the Personal

Data was entered into, modified on or removed from a data processing system.

Ensure that in the case where Processing is carried out by a Data Processor, the data can

be Processed only in accordance with the instructions of the Data Controller.

Ensure that Personal Data is protected against undesired destruction or loss.
Ensure that Personal Data is not kept longer than necessary.
Regularly evaluate and test the effectiveness of safeguards to ensure security of

Processing of Personal Data.

3.7. Data Subject Rights

3.7.1. The process for attending to the following Data Subject rights is outlined in the Data Subject Access Policy:

information access
• objection to Processing.
• objection to automated decision-making and Profiling • restriction of Processing
• data portability
• data rectification
• data erasure.

No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be unnecessary or excessive in nature.

3.7.2. Data Subjects are entitled to, based upon a request made in and upon successful verification of their identity, the following information about their own Personal Data:

the purposes of the collection, Processing, use and storage of their Personal Data
the source(s) of the Personal Data, if it was not obtained from the Data Subject
the categories of Personal Data stored for the Data Subject
the recipients, or categories of recipients, to whom the Personal Data has been or may be

transmitted, along with the location of those recipients

the envisaged period of storage for the Personal Data or the rationale for determining the

storage period

the use of any automated decision-making, including Profiling
the retention periods applied to the data
a summary of the security measures in place to protect the data
request to erase Personal Data if it is no longer necessary in relation to the purposes for

which it was collected or Processed or to rectify inaccurate data or to complete incomplete data.

3.7.3. A response to each request will be provided within 30 days of the receipt of the written request from the Data Subject. That period may be extended by two further months where necessary, considering the complexity and number of the requests.
3.7.4. Appropriate verification must confirm that the requestor is the Data Subject or their authorised legal representative. Data Subjects shall have the right to require BNM Analytics Limited to correct or supplement erroneous, misleading, outdated, or incomplete Personal Data.
3.7.5. Please refer to the Individuals Rights Policy for detailed guidance and procedures for responding to such requests.

Third-Party Data

3.7.6. It should be noted that situations may arise where providing the information requested by a Data Subject would disclose Personal Data about another individual. In such cases, information must be redacted or withheld as may be necessary or appropriate to protect that person’s rights.
3.7.7. When Personal Data is collected indirectly (for example, from a third party or publicly available source), BNM Analytics Limited will provide the Data Subject with all the information required by the GDPR as soon as possible after collecting/receiving the data. BNM Analytics Limited will also check that the Personal Data was collected by the third party in accordance with the GDPR and on a basis which contemplates proposed Processing of that Personal Data.

3.8. Law Enforcement Requests and Disclosures

3.8.1. In certain circumstances, it is permitted that Personal Data be shared without the knowledge or Consent of a Data Subject. This is the case where the disclosure of the Personal Data is necessary for any of the following purposes:

the prevention or detection of crime;
the apprehension or prosecution of offenders
the assessment or collection of a tax or duty
by order of a court or by any rule of law.

3.9. Data Protection Training

3.9.1. All BNM Analytics Limited Employees and Employees of Third Parties (Data Processors) that have access to Personal Data will have their responsibilities under this policy outlined to them as part of their staff induction training. In addition, BNM Analytics Limited and Third Parties will provide regular Data Protection training and procedural guidance for their staff.

3.9.2. The training and procedural guidance set forth will consist of, at a minimum, the following elements:

the Data Protection Principles set forth in Section 4.2 above
• each Employee’s duty to use and permit the use of Personal Data only by authorised

persons and for authorised purposes
• the need for, and proper use of, the forms and procedures adopted to implement this

policy
• the correct use of passwords, security tokens and other access mechanisms
• the importance of limiting access to Personal Data, such as by using password protected

screen savers and logging out when systems are not being attended by an authorised

person
• securely storing manual files, printouts and electronic storage media
• information on how to detect a phishing email
• proper disposal of Personal Data by using secure shredding facilities
• any special risks associated with particular departmental activities or duties.

3.10. Data Transfer

3.10.1. BNM Analytics Limited may transfer Personal Data to internal or Third-Party recipients located in another country where that country is recognised as having an adequate level of legal protection for the rights and freedoms of the relevant Data Subjects.
3.10.2. Where transfers need to be made to countries lacking an adequate level of legal protection (i.e. Third Countries), they must be made in compliance with an approved transfer mechanism.
3.10.3. BNM Analytics Limited may only transfer Personal Data where one of the transfer scenarios listed below applies:

the Data Subject has given Consent to the proposed transfer.
• the transfer is necessary for the performance of a contract with the Data Subject
• the transfer is necessary for the implementation of pre-contractual measures taken in

response to the Data Subject’s request
• the transfer is necessary for the conclusion or performance of a contract concluded

with a Third Party in the interest of the Data Subject.
• the transfer is legally required on important public interest grounds
• the transfer is necessary for the establishment, exercise or defence of legal claims • the transfer is necessary in order to protect the vital interests of the Data Subject.

Transfers to Third Parties

3.10.4. BNM Analytics Limited will only transfer Personal Data to, or allow access by, Third Parties when it is assured that the information will be Processed legitimately and protected appropriately by the recipient. Where Third-Party Processing takes place, BNM Analytics Limited will first identify if, under applicable law, the Third Party is considered a Data Controller, or a Data Processor of the Personal Data being transferred.
3.10.5. Where the Third Party is deemed to be a Data Controller, BNM Analytics Limited will enter into an appropriate agreement with the Controller to clarify each party’s responsibilities in respect to the Personal Data transferred.

3.10.6. Where the Third Party is deemed to be a Data Processor, will enter into an adequate Processing agreement with the Data Processor. The agreement must require the Data Processor to protect the Personal Data from further disclosure and to only Process Personal Data in compliance with BNM Analytics Limited instructions. In addition, the agreement will require the Data Processor to implement appropriate technical and organisational measures to protect the Personal Data, as well as procedures for providing notification of Personal Data Breaches.
3.10.7. When outsourcing services to a Third Party (including Cloud Computing services), BNM Analytics Limited will identify whether the Third Party will Process Personal Data on its behalf and whether the outsourcing will entail any Third Country transfers of Personal Data.
3.10.8. Regular audits of Processing of Personal Data performed by Third Parties, especially in respect of technical and organisational measures they have in place, should be undertaken. Any major deficiencies identified will be reported to and monitored by BNM Analytics Limited Management Team.

3.11. Complaints Handling

3.11.1. Data Subjects with a complaint about the Processing of their Personal Data should put forward the matter in writing. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case. BNM Analytics Limited will inform the Data Subject of the progress and the outcome of the complaint within a reasonable period.
3.11.2. If the issue cannot be resolved through consultation with the Data Subject, then the Data Subject should be advised that they may, at their option, seek redress through mediation, binding arbitration, litigation, or via a complaint to the Information Commissioner’s Office (ICO).

3.12. Breach Reporting

3.12.1. Any individual who suspects that a Personal Data Breach has occurred due to the theft or exposure of Personal Data must immediately notify the DPO providing a description of what occurred. Notification of the incident can be made via e-mail to Data Protection Officer should update the internal breach log, including pertinent facts relating to the incident, effects and remedial actions taken.
3.12.2. All reported incidents will be investigated to confirm whether or not a Personal Data Breach has occurred. For severe Personal Data Breaches, BNM Analytics Limited must inform the ICO within 72 hours of becoming aware of the breach. In some cases, affected Data Subjects should be advised of the personal data breach.
3.12.3. Guidance can be found in the Incident Management Policy.

Policy Maintenance 4.1 Publication

4.1.1. This policy shall be available to all Employees through BNM Analytics Limited web site in the case of areas which employ non-desk-based employees, then a hard copy will be made available in the office.

Effective Data and Revision

5.1 Effective Date – 14th April 2020

5.2 Revisions – as released by The GDPR and Data Protection Compliance Consultancy Limited, this version 1.5

6 Related documents

Individual Rights Policy
Incident Management Policy
Data Retention Policy

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