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Data protection and Confidentiality GDPR


The EU General Data Protection Regulation (“GDPR”) came into force on 25 May 2018.

The new Regulation aims to standardise data protection laws and processing across the EU, giving people greater rights to access and control their personal information.

Our Commitment

Geoff Greenfield Limited are committed to ensuring protection of all personal information that we hold, and to provide and to protect all such data. We recognise our obligations in updating and expanding this program to meet the requirements of GDPR.

Geoff Greenfield Limited are dedicated to safeguarding the personal information under our control and in maintaining a system that meets our obligations under the new regulations. Our practice is summarised below.

How We Prepared for GDPR

Geoff Greenfield Limited already have a consistent level of data protection and security across our organisation, but we have introduced new measures to ensure compliancy.

  • Policies and Procedures — we have revised data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
    • Data Protection – our main policy and procedure document for data protection has been revised to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities, with a dedicated focus on privacy and the rights of individuals.
    • Data Retention and Erasure – we have updated our retention policy and schedule to ensure that we meet the “data minimisation” and “storage limitation” principles and that personal information is stored, archived, and destroyed in accordance with our obligations. 
  • Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.  This is disclosed on our website.

Data Subject Rights

We provide easy-to-access information via our website of an individual’s right to access any personal information that Geoff Greenfield Limited processes about them and to request information about:

  • what personal data we hold about them
  • the purposes of the processing
  • the categories of personal data concerned
  • the recipients to whom the personal data has/will be disclosed
  • how long we intend to store your personal data for
  • if we did not collect the data directly from them, information about the source
  • the right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
  • the right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
  • the right to lodge a complaint or seek judicial remedy and who to contact in such instances.

Information Security and Technical and Organisational Measures

Geoff Greenfield Limited takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction.

All laptops, pc’s and phones are password protected.  All items have firewall security and anti-virus installed.


The Company operates in a highly competitive environment. During your employment, you may have access to sensitive commercial information such as prices, salaries, suppliers, customer addresses etc.  You must not pass on this information either during or after termination of your employment, without express permission from the Company.  

In addition, you must not directly or indirectly use or exploit, for your own purposes or those of any person, company, business entity or other organisation any confidential information belonging to the Company.  Examples of confidential information are, but are not limited to: 

  • the identity of customers including their names and addresses and where relevant, the identity of any key person within that organisation with whom the Company deals.
  • details of pricing structures.
  • details of services supplied to customers.
  • marketing information collected or collated.
  • business plans, dealings or negotiations with customers, suppliers or others relating to the business of the Company.
  • financial information including accounts, management accounts, budgets, projections, or similar information relating to the Company
  • manuals, technical information or data, procedures, processes, formulae, or teaching material prepared or created by the Company

Honesty and Integrity

Everybody is responsible for the security of equipment, supplies and confidential information within the Company.  You are expected to carry out your duties for the Company in good faith and to remain entirely honest and truthful in all your dealings in relation to the Company and its management, customers, and business suppliers.  

You are to notify the Company promptly if you are convicted of a criminal offence, which relates either directly or indirectly to your employment, giving details of the offence, penalty, and date of conviction.

Data Protection Act

Under the Data Protection Act, you have a duty to treat all customer and supplier information or data that could be thought of as ‘personal’, with the utmost care and privacy and do the best you can to keep personal information private.  You should make yourself aware of the eight Data Protection Act Principles.  If you have any questions, please refer these to the Operations Manager.