Data protection policy of Shrinkpad Designs Limited

Shrinkpad Designs Limited is committed to being transparent about how it collects and uses the personal data including, in particular, the data of our employees, suppliers, and actual and potential clients/customers of our services. This policy applies to the personal data of all such persons. 

Data protection principles
• Shrinkpad Designs Limited processes personal data in accordance with the following data protection principles:
• Shrinkpad Designs Limited processes personal data lawfully, fairly and in a transparent manner.
• Shrinkpad Designs Limited collects personal data only for specified, explicit and legitimate purposes.
• Shrinkpad Designs Limited processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
• Shrinkpad Designs Limited keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
• Shrinkpad Designs Limited keeps personal data only for the period necessary for processing.
• Shrinkpad Designs Limited adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

Shrinkpad Designs Limited tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons. Where Shrinkpad Designs Limited relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.

The legal basis on Which we hold personal data
We hold personal data under the following permitted reasons provided by the GDPR. One of these reasons will apply to your data:
(a) Consent: the individual has given clear consent for Shrinkpad Designs Limited to process their personal data for a specific purpose, for example: the client has input their details via MailChimp to sign up to our newsletter.
(b) Contract: the processing is necessary for a membership contract Shrinkpad Designs Limited has with the individual, or because they have asked you to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary for Shrinkpad Designs Limited to comply with the law (not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life, for example, next of kin data / emergency contact data in case of emergency.
(e) Public task: the processing is necessary for Shrinkpad Designs Limited to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for Shrinkpad Designs Limited’s legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. 

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, Shrinkpad Designs Limited will tell him/her:
• whether or not his/her 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 his/her 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 his/her personal data is stored (or how that period is decided);
• his/her rights to rectification or erasure of data, or to restrict or object to processing;
• his/her right to complain to the Information Commissioner if he/she thinks Shrinkpad Designs Limited has failed to comply with his/her data protection rights; and
• whether or not Shrinkpad Designs Limited carries out automated decision-making and the logic involved in any such decision-making.

Shrinkpad Designs Limited 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 he/she agrees otherwise.
To make a subject access request, the individual should send the request via the online form, or email directly.
In some cases, Shrinkpad Designs Limited may need to ask for proof of identification before the request can be processed. Shrinkpad Designs Limited will inform the individual if it needs to verify his/her identity and the documents it requires.
Shrinkpad Designs Limited will normally respond to a request within a period of one month from the date it is received. In some cases, such as where Shrinkpad Designs Limited processes large amounts of the individual's data, it may respond within three months of the date the request is received. Shrinkpad Designs Limited will write to the individual within one month of receiving the original request to tell him/her if this is the case.
If a subject access request is manifestly unfounded or excessive, Shrinkpad Designs Limited is not obliged to comply with it. Alternatively, Shrinkpad Designs Limited can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which Shrinkpad Designs Limited has already responded. If an individual submits a request that is unfounded or excessive, Shrinkpad Designs Limited will notify him/her that this is the case and whether or not it will respond to it.

Other rights
Individuals have a number of other rights in relation to their personal data. They can require Shrinkpad Designs Limited 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 Shrinkpad Designs Limited's legitimate grounds for processing data (where Shrinkpad Designs Limited relies on its legitimate interests as a reason for processing data);
• stop processing or erase data if processing is unlawful; and
• 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 Shrinkpad Designs Limited's legitimate grounds for processing data.

To ask Shrinkpad Designs Limited to take any of these steps, the individual should send the request via the online form, or email directly.

Data security
Shrinkpad Designs Limited takes the security of personal data seriously. Shrinkpad Designs Limited has 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. 

Data breaches
If Shrinkpad Designs Limited discovers that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. Shrinkpad Designs Limited will record all data breaches regardless of their effect.

Clients
Individuals are responsible for helping Shrinkpad Designs Limited keep their personal data up to date. Individuals should let Shrinkpad Designs Limited know if data provided to Shrinkpad Designs Limited changes, for example if an individual moves house or changes his/her bank details.
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