Data Protection Policy

Ventro Ltd needs to collect and use certain types of information about customers and other individuals who come into contact with Ventro.  This personal information must be dealt with properly however it is collected, recorded and used – whether on paper, in a computer, or recorded on other material – and there are safeguards to ensure this in Data Protection Legislation.

Ventro Ltd regards the lawful and correct treatment of personal information as very important and
therefore ensures that personal information is treated lawfully and correctly. To this end Ventro fully
endorses and adheres to the Principles of Data Protection, as detailed in the Data Protection Act 1998 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) which became
enforceable on 25th May 2018.

Ventro Ltd is an ICO-registered data controller and processor (registration no. ZA484399). 

Specifically, the Principles require that personal information:

1. Shall be processed fairly and lawfully and, in particular, shall not be processed unless
   specific conditions are met.
2. Shall be obtained only for one or more specified and lawful purposes, and shall not be
   further processed in any manner incompatible with that purpose or those purposes.
3. Shall be adequate, relevant and not excessive in relation to the purpose or purposes for
   which they are processed.
4. Shall be accurate and, where necessary, kept up to date.
5. Shall not be kept for longer than is necessary for that purpose or those purposes.
6. Shall be processed in accordance with the rights of data subjects.
7. Appropriate technical and organisational measures shall be taken against unauthorised or
   unlawful processing of personal data and against accidental loss or destruction of, or
   damage to, personal data.
8. Shall not be transferred to a country or territory outside the European Economic Area
   unless that country or territory ensures an adequate level of protection for the rights and
   freedoms of data subjects in relation to the processing of personal data.

Ventro will, through appropriate management and strict application of criteria and controls:

1. Observe fully conditions regarding the fair collection and use of information.
2. Meet its legal obligations to specify the purposes for which information is used.
3. Collect and process appropriate information, and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements.
4. Ensure the quality of information used.
5. Apply strict checks to determine the length of time information is held.
6. Ensure that the rights of people about whom information is held, can be fully exercised
   under the Act. (These include: the right to be informed that processing is being
   undertaken, the right of access to one’s personal information, the right to prevent
   processing in certain circumstances and the right to correct, rectify, block or erase
   information which is regarded as wrong information).
7. Take appropriate technical and organisational security measures to safeguard personal
   information.
8. Ensure that personal information is not transferred abroad without suitable safeguards.
9. Treat people justly and fairly whatever their age, religion, disability, gender, sexual
   orientation or ethnicity when dealing with requests for information.
10. Set out clear procedures for responding to requests for information.

In addition, Ventro will ensure that:

1. There is someone with specific responsibility for Data Protection. Ventro’s Data Protection
   Officer is Harvey Melvin.
2. Everyone managing and handling personal information understands that they are contractually responsible for following good data protection practice.
3. Everyone managing and handling personal information is appropriately trained to do so.
4. Everyone managing and handling personal information is appropriately supervised.
5. Anybody wanting to make enquiries about handling personal information knows what to
   do.
6. Queries about handling personal information are promptly and courteously dealt with.
7. Methods of handling personal information are clearly described.
8. A regular review and audit is made of the way personal information is held, managed and
   used.
9. Methods of handling personal information are regularly assessed and evaluated.
10. Performance with handling personal information is regularly assessed and evaluated.
11. A breach of the rules and procedures identified in this policy by a member of staff may
    lead to disciplinary action being taken.

The Controller for the purposes of the General Data Protection Regulation (GDPR), other data
protection laws applicable in Member states of the European Union and other provisions related to
data protection is: Ross Melvin

This policy will be updated as necessary to reflect best practice in data management, security and
control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998 and/or GDPR.