Data Protection Policy - ComponentSource Group

1. Introduction

This Policy sets out the obligations of the COMPONENTSOURCE GROUP, comprising companies registered in England, the Republic of Ireland, the United States of America and Japan (“ComponentSource” or “the Company”) concerning data protection and the rights of customers, suppliers, publishers, employees and business contacts (“Data Subjects”) in respect of their personal data under Applicable Data Protection Laws in the jurisdictions where it is present or conducts business including in particular EU Regulation 2016/679 General Data Protection Regulation (“GDPR”) https://gdpr-info.eu, the UK General Data Protection Regulation and the UK Data Protection Act 2018 (collectively “UK GDPR”), the EU-US Data Privacy Framework (“DPF”) and the UK Extension to the EU-US DPF, a self-certification program operated by the US Department of Commerce, and the California Consumer Privacy Act 2018, as amended (Cal.Civ.Code 1798.100 to 1798.199)(“CCPA”), or their equivalents, including any legislated amendments to any of these laws. To the extent other Applicable Data Protection Laws apply that are substantially similar to the GDPR, the UK GDPR, or the CCPA, this Policy will be interpreted reasonably to apply to such other jurisdictions and laws.
The Applicable Data Protection Laws defines “Personal Data” as any information relating to an identified or identifiable natural person (a Data Subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, street or email address, telephone number, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
This Policy sets out the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of Personal Data. The procedures and principles set out in this Policy should be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
ComponentSource is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all Personal Data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

2. The Data Protection Principles

This Policy aims to ensure compliance with all GDPR and all Applicable Data Protection Laws. Applicable Data Protection Laws set out the following principles with which any party handling Personal Data must comply. All Personal Data must be:

Processed lawfully, fairly, and in a transparent manner in relation to the Data Subject;
Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for statistical purposes will not be considered to be incompatible with the initial purposes;
Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;
Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that Personal Data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay;
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. Personal data may be stored for longer periods insofar as the Personal Data will be processed solely for statistical purposes, or as otherwise permitted by the Applicable Data Protection Laws including the legitimate operational needs of our business (subject to implementation of the appropriate technical and organisational measures required by the Applicable Data Protection Laws in order to safeguard the rights and freedoms of the Data Subject).
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, using appropriate technical or organisational measures.

3. The Rights of Data Subjects

Applicable Data Protection Laws set out the following rights applicable to Data Subjects (please refer to the parts of this policy indicated for further details):

The right to be informed (Section 12).
The right of access (Section 13);
The right to rectification (Section 14);
The right to erasure (also known as the ‘right to be forgotten’) (Section 15);
The right to restrict processing (Section 16);
The right to object (Section 17); and
Rights with respect to automated decision-making and profiling (Sections 18 and 19).

4. Lawful, Fair, and Transparent Data Processing

Applicable Data Protection Laws seek to ensure that Personal Data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the Data Subject. Applicable Data Protection Laws state that processing of Personal Data will be lawful if at least one of the following applies:

The Data Subject has given consent to the processing of their Personal Data for one or more specific purposes;
The processing is necessary for the performance of a contract to which the Data Subject is a party, or in order to take steps at the request of the Data Subject prior to entering into a contract with them;
The processing is necessary for compliance with a legal obligation to which the data controller is subject;
The processing is necessary to protect the vital interests of the Data Subject or of another natural person;
The 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; or
The 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 fundamental rights and freedoms of the Data Subject which require protection of Personal Data, in particular where the Data Subject is a child.

5. Specified, Explicit, and Legitimate Purposes

ComponentSource collects and processes the Personal Data set out in Section 20 of this Policy. This includes:

Personal Data collected directly from Data Subjects; and
Personal Data obtained from third parties.

The Company only collects, processes, and holds Personal Data for the specific purposes set out in Section 20 of this Policy (or for other purposes expressly permitted by the Applicable Data Protection Laws).

Data Subjects will be kept informed of the purpose or purposes for which ComponentSource uses their Personal Data. Please refer to Section 12 for more information on keeping Data Subjects informed.

6. Adequate, Relevant, and Limited Data Processing

ComponentSource will only collect and process Personal Data for and to the extent necessary for the specific purpose or purposes of which Data Subjects have been informed (or will be informed) as under Section 5, above, and as set out in Section 20, below.

7. Accuracy of Data and Keeping Data Up-to-Date

ComponentSource seeks to ensure as reasonably necessary that all Personal Data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of Personal Data at the request of a Data Subject, as set out in Section 14, below.
The accuracy of Personal Data will be checked when it is collected. If subsequently any Personal Data change is notified to ComponentSource or any Personal Data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

8. Data Retention

Subject to the legitimate operational needs of its business ComponentSource will not keep Personal Data for any longer than is necessary in light of the purpose or purposes for which that Personal Data was originally collected, held, and processed.
When Personal Data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
For full details of the Company’s approach to data retention, including retention periods for specific Personal Data types held by ComponentSource, please refer to our Data Retention Policy.

9. Secure Processing

ComponentSource will ensure that all Personal Data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which should be taken are provided in Sections 20 to 26 of this Policy.

10. Accountability and Record-Keeping

The Company’s Data Protection Manager ("DPM") can be contacted at dpm@componentsource.com.

The DPM will be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with all Applicable Data Protection Laws. ComponentSource will keep internal records of all Personal Data collection, holding, and processing, which will incorporate the following information:

The name and details of the Company, its DPM, and any applicable third-party data processors;
The purposes for which the Company collects, holds, and processes Personal Data;
Details of the categories of Personal Data collected, held, and processed by the Company, and the categories of data subject to which that Personal Data relates;
Details of any transfers of Personal Data to non-EEA countries including all mechanisms and security safeguards;
Details of how long Personal Data will be retained by the Company (please refer to the ComponentSource Data Retention Policy); and
Detailed descriptions of all technical and organisational measures taken by ComponentSource to ensure the security of Personal Data.

11. Data Protection Impact Assessments

ComponentSource will carry out Data Protection Impact Assessments for any and all new projects and/or new uses of Personal Data.

Data Protection Impact Assessments will be overseen by the Data Protection Manager and will address the following:

The type(s) of Personal Data that will be collected, held, and processed;
The purpose(s) for which Personal Data is to be used;
The Company’s objectives;
How Personal Data is to be used;
The parties (internal and/or external) who are to be consulted;
The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
Risks posed to Data Subjects;-
Risks posed both within and to the Company; and
Proposed measures to minimise and handle identified risks.

12. Keeping Data Subjects Informed

Upon request from a Data Subject ComponentSource will provide within 5 business days the information set out in Section 12.2 to the Data Subject:
1. Where Personal Data is collected directly from Data Subjects, those Data Subjects will be informed of its purpose at the time of collection; and
2. Where Personal Data is obtained from a third party, the relevant Data Subjects will be informed of its purpose:
  1. if the Personal Data is used to communicate with the Data Subject, when the first communication is made; or
  2. if the Personal Data is to be transferred to another party, before that transfer is made; or
  3. as soon as reasonably possible and in any event not more than one month after the Personal Data is obtained.
The following information will be made available upon request to Data Subjects:
1. Details of the Company including, but not limited to, the contact details of its DPM;
2. The purpose(s) for which the Personal Data is being collected and will be processed (as detailed in Section 20 of this Policy);
3. Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the Personal Data;
4. Where the Personal Data is not obtained directly from the Data Subject, the categories of Personal Data collected and processed;
5. v. Where the Personal Data is to be transferred to one or more third parties, details of those parties;
6. Where the Personal Data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Section 27 of this Policy for further details);
7. Details of data retention;
8. Details of the Data Subject’s rights under Applicable Data Protection Laws;
9. Details of the Data Subject’s right to withdraw their consent to the Company’s processing of their Personal Data at any time;
10. Details of the Data Subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the UK GDPR) or where applicable to equivalent authorities in the Republic of Ireland, the USA and Japan;
11. Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the Personal Data and details of any consequences of failing to provide it; and
12. Details of any automated decision-making or profiling that will take place using the Personal Data, including information on how decisions will be made, the significance of those decisions, and any consequences.

13. Data Subject Access

Data Subjects may make subject access requests (“SARs”) at any time to find out more about the Personal Data which ComponentSource holds about them, what it is doing with that Personal Data, and why.
Data Subjects wishing to make a SAR should do using a Subject Access Request Form, sending the form to the DPM at dpm@componentsource.com
Responses to SARs will normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the Data Subject will be informed.
All SARs received will be handled by the DPM.
ComponentSource does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a Data Subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

14. Rectification of Personal Data

Data Subjects have the right to require ComponentSource to rectify any of their Personal Data that is inaccurate or incomplete.
ComponentSource will rectify the Personal Data in question, and inform the Data Subject of that rectification, within one month of the Data Subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the Data Subject will be informed.
In the event that any affected Personal Data has been disclosed to third parties, those parties will be informed of any rectification that must be made to that Personal Data on or before the processing of the next transaction.

15. Erasure of Personal Data

Data Subjects have the right to request that ComponentSource erases the Personal Data it holds about them in the following circumstances:
1. It is no longer necessary for the Company to hold that Personal Data with respect to the purpose(s) for which it was originally collected or processed;
2. The Data Subject wishes to withdraw their consent to ComponentSource holding and processing their Personal Data;
3. The Data Subject objects to ComponentSource holding and processing their Personal Data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Section 17 of this Policy for further details concerning the right to object);
4. The Personal Data has been processed unlawfully;
5. The Personal Data needs to be erased in order for ComponentSource to comply with a particular legal obligation.
Unless ComponentSource has reasonable grounds to refuse to erase Personal Data, all requests for erasure will be complied with, and the Data Subject informed of the erasure, within one month of receipt of the Data Subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the Data Subject will be informed.
In the event that any Personal Data that is to be erased in response to a Data Subject’s request has been disclosed to third parties, those parties will be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).
The erasure of Personal Data will not extend to internal ComponentSource records detailing the circumstances (request and compliance) of the erasure, nor will any erasure take place that would be detrimental to the effective operation of the Company’s anti-fraud systems.

16. Restriction of Personal Data Processing

Data Subjects may request that ComponentSource ceases processing the Personal Data it holds about them. If a Data Subject makes such a request, the Company will retain only the amount of Personal Data concerning that Data Subject (if any) that is necessary to ensure that the Personal Data in question is not processed further.

NB: Data Subjects will be warned that compliance by ComponentSource could necessitate the revocation of ongoing software licences and will be given the opportunity to withdraw or amend their request prior to its implementation.
In the event that any affected Personal Data has been disclosed to third parties, those parties will be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

17. Objections to Personal Data Processing

Data Subjects have the right to object to ComponentSource processing their Personal Data based on legitimate interests, direct marketing (including profiling), and processing for statistical purposes.
Where a Data Subject objects to ComponentSource processing their Personal Data based on its legitimate interests, the Company will cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the Data Subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.
Where a Data Subject objects to ComponentSource processing their Personal Data for direct marketing purposes, the Company will cease such processing immediately.

18. Automated Decision-Making

The Company uses Personal Data in automated decision-making processes.
Where such decisions have a legal (or similarly significant effect) on Data Subjects, those Data Subjects have the right to challenge such decisions under the Applicable Data Protection Laws, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.
The right described in Section 18.2 does not apply in the following circumstances:
1. The decision is necessary for the entry into, or performance of, a contract between the Company and the Data Subject;
2. The decision is authorised by law; or
3. The Data Subject has given their explicit consent.

19. Profiling

The Company uses Personal Data generically for profiling purposes in order to maximise the usefulness and effectiveness of its customer services.
When Personal Data is used for profiling purposes, the following will apply:
1. Technical and organisational measures will be implemented to minimise the risk of errors. If errors occur, such measures should enable them to be easily corrected; and
2. All Personal Data processed for profiling purposes will be secured in order to prevent discriminatory effects arising out of profiling (see Sections 21 to 25 of this Policy for more details on data security).

20. Personal Data Collected, Held, and Processed

The following personal data is collected, held, and processed by ComponentSource (for details of data retention, please refer to the Company’s Data Retention Policy):

Data Reference	Type of Data	Purpose of Data
Customer	Name	Quote creation, order processing, authentication & software delivery
Customer	Organisation name and type	Customer registration, quote creation, order processing, authentication & software delivery
Customer	Address (including street, county/state, zip or post code, country)	Quote creation, order processing, authentication & software delivery, paper catalogue delivery, promotional item delivery (coffee mug)
Customer	Email Address	Customer registration, quote creation, order processing, authentication & software delivery, Product news, customer email newsletter delivery, customer communications
Customer	Telephone number	Quote creation, order processing & software delivery, customer communications

Data Reference	Type of Data	Purpose of Data
Customer	IP address	Quote creation, order processing, authentication, payment processing & software delivery
Customer	Bank Account Numbers, Sort Code, Account Name	Order processing and payment processing
Customer	Credit/Debit Card Number, Card Holder Name, Expiry Date and CV2 number (CV2 is only used per transaction and never stored)	Order processing, payment processing, authentication and verification
End User Licensee	Name (if different from Customer)	Quote creation, order processing, authentication & software delivery
End User Licensee	Organisation name and type	Licensee registration with Publisher, quote creation, order processing, authentication & software delivery
End User Licensee	Address (including street, county/state, zip or post code, country)	Quote creation, order processing, authentication & software delivery
End User Licensee	Email address	Quote creation, order processing, authentication, & software delivery, licensee communications
End User Licensee	Telephone number	Quote creation, order processing & software delivery, licensee communications
End User Licensee	IP address	Quote creation, order processing, authentication, payment processing & software delivery
Publisher	Name, Address, Email Address, Telephone number, Bank Account Details	Order processing, payment processing and software delivery
Supplier	Name, Address, Email Address, Telephone number, Bank Account Details	Order processing, payment processing and delivery
Shareholder	Name, Address, Email Address, Telephone number, Bank Account Details	Shareholder communications, company returns and registers, plus payment processing
Employee/ Director/ Contractor	Name, Address, Email Address, Telephone number, National Insurance number, Tax Codes, Bank Account Details and all other information required in connection with the operation and administration of their employment contracts	Data usage in the individual Privacy Notice Schedules to their Employment Contracts or Contracts of Engagement

21. Data Security - Transferring Personal Data and Communications

ComponentSource will ensure that the following measures are taken with respect to all communications and other transfers involving Personal Data:
1. Credit card data provided to the Company on its website will be encrypted;
2. All emails containing Personal Data, whether sent or received, will be stored securely.
3. Where Personal Data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using recognised mail or delivery services.

22. Data Security - Storage

ComponentSource will ensure that the following measures are taken with respect to the storage of Personal Data:
1. All electronic copies of Personal Data should be stored securely;
2. All hardcopies of Personal Data, along with any electronic copies stored on physical, removable media should be stored securely;
3. All Personal Data stored electronically should be backed up regularly with backups stored offsite whenever practicable;
No Personal Data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to ComponentSource or otherwise without the written authorisation of the Data Protection Manager and, in the event of such authorisation, strictly in accordance with all instructions and limitations described in the authorisation, and for no longer than is absolutely necessary; and
No Personal Data should be transferred to any device personally belonging to an employee and Personal Data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of all Applicable Data Protection Laws (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).

23. Data Security - Disposal

When any Personal Data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.

24. Data Security - Use of Personal Data

ComponentSource will ensure that the following measures are taken with respect to the use of Personal Data:

No Personal Data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of ComponentSource requires access to any Personal Data that they do not already have access to, such access should be formally requested from the DPM;
No Personal Data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of ComponentSource or not, without the authorisation of the DPM;
Personal Data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;
If Personal Data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user should lock the computer and screen before leaving it; and
Where Personal Data held by ComponentSource is used for marketing purposes, it will be the responsibility of the DPM to ensure that the appropriate consent is obtained and that no Data Subjects have opted out, whether directly or via a third-party service.

25. Data Security - IT Security

ComponentSource will ensure that the following measures are taken with respect to IT and information security:

All passwords used to protect Personal Data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. It is recommended that all passwords should contain a combination of uppercase and lowercase letters, numbers, and symbols;
Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of ComponentSource, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
All software (including, but not limited to, applications and operating systems) will be kept up-to-date wherever commercially practicable. The Company’s IT staff are responsible for installing any and all security-related updates promptly after the updates are made available by the publisher or manufacturer unless there are valid technical reasons not to do so; and
No software may be installed on any Company-owned computer or device without the prior approval of the CIO or the DPM.

26. Organisational Measures

ComponentSource will ensure that the following measures are taken with respect to the collection, holding, and processing of Personal Data:

All employees, agents, contractors provided with a copy of this Policy;
Only employees, agents, sub-contractors, or other parties working on behalf of ComponentSource that need access to, and use of, Personal Data in order to carry out their assigned duties correctly will have access to Personal Data held by ComponentSource;
All employees, agents, contractors, or other parties working on behalf of ComponentSource handling Personal Data will be appropriately trained to do so;
All employees, agents, contractors, or other parties working on behalf of ComponentSource handling Personal Data will be appropriately supervised;
All employees, agents, contractors, or other parties working on behalf of ComponentSource handling Personal Data will be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to Personal Data, whether in the workplace or otherwise;
Methods of collecting, holding, and processing Personal Data will be regularly evaluated and reviewed;
All Personal Data held by ComponentSource will be reviewed periodically, as set out in the Company’s Data Retention Policy;
The performance of those employees, agents, contractors, or other parties working on behalf of ComponentSource handling Personal Data will be regularly evaluated and reviewed;
All employees, agents, contractors, or other parties working on behalf of ComponentSource handling personal data will be bound to do so in accordance with the principles of all Applicable Data Protection Laws and this Policy by contract;
All agents, contractors, or other parties working on behalf of ComponentSource handling Personal Data must ensure that any and all of their employees who are involved in the processing of Personal Data are held to the same conditions as those relevant employees of the Company arising out of this Policy and Applicable Data Protection Laws; and
Where any agent, contractor or other party working on behalf of ComponentSource handling Personal Data fails in their obligations under this Policy that party will indemnify and hold ComponentSource harmless from and against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

27. Transferring Personal Data to a Country Outside the EEA

All Personal Data resides on the Company’s servers in its offices in the UK, Republic of Ireland, the USA and Japan. ComponentSource may from time to time transfer (‘transfer’ includes making available remotely) Personal Data to other countries outside of the EEA.
The transfer of Personal Data to a country outside of the EEA will take place only if one or more of the following applies:
1. The transfer is made with the informed consent of the relevant Data Subject(s), for example where End User Licensee data is transferred to the Software Publisher/Owner as a condition of the License;
2. The transfer is necessary for the performance of a contract between the Data Subject and ComponentSource (or for pre-contractual steps taken at the request of the Data Subject);
3. The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the source country has determined ensures an adequate level of protection for Personal Data;
4. The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted in Applicable Data Protection Laws; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office in the UK); certification under an approved certification mechanism (as provided for in Applicable Data Protection Laws); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
5. The transfer is necessary for important public interest reasons;
6. The transfer is necessary for the conduct of legal claims;
7. The transfer is necessary to protect the vital interests of the Data Subject or other individuals where the Data Subject is physically or legally unable to give their consent; or
8. The transfer is made from a register that, under Applicable Data Protection Laws, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

28. Data Breach Notification

All Personal Data breaches must be reported urgently following discovery to the DPM.
If a Personal Data breach occurs and that breach is likely to result in a risk to the rights and freedoms of Data Subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the DPM must ensure that the relevant supervising authority is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
In the event that a Personal Data breach is likely to result in a high risk (that is, a higher risk than that described under Section 28b) to the rights and freedoms of Data Subjects, the DPM should ensure that all affected Data Subjects are informed of the breach directly and without undue delay.
Data breach notifications should include the following information:
1. The categories and approximate number of Data Subjects concerned;
2. The categories and approximate number of Personal Data records concerned;
3. The name and contact details of the DPM (or other contact point where more information can be obtained);
4. The likely consequences of the breach;
5. Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

29. Implementation of Policy

The effective date of this Policy is 1st November 2025.

CSDPP 10/2025