Contract analysis

1. Introduction and Purpose 1.1 Purpose of this Policy This Group Data Protection Policy (this "Policy") establishes the overarching framework for the protection of personal data processed by Northgate Telecommunications PLC ("NTP" or the "Company") and all of its subsidiaries and affiliates operating across the United Kingdom and the European Union (collectively, the "Group" or "NTP Group"). It sets out the principl

2. Scope 2.1 Organisational Scope This Policy applies to Northgate Telecommunications PLC and to each of its subsidiaries and affiliated entities within the NTP Group. As at the date of this Policy, the NTP Group comprises the following entities: Northgate Telecommunications PLC (the parent company), incorporated and registered in England and Wales under Company Number 04837291, with its registered office at 140 Quee

3. Definitions and Interpretation 3.1 Key Defined Terms Unless the context otherwise requires, the following terms shall have the meanings set out below when used in this Policy. Where a term is defined in Article 4 of the UK GDPR or Article 4 of the EU GDPR, the definition in this Policy is intended to be consistent with, and shall be interpreted in accordance with, the relevant statutory definition. "Automated Deci

4. Data Protection Principles 4.1 Overview of Principles The UK GDPR and the EU GDPR each establish a set of fundamental principles that govern the processing of personal data. These principles, set out in Article 5 of each regulation, are the foundation upon which all of NTP's data protection obligations are built. The NTP Group is committed to ensuring that all processing of personal data complies with each of thes

5. Lawful Basis for Processing 5.1 Overview of Lawful Bases

Article 6(1) of the UK GDPR and the EU GDPR provides that the processing of personal data is lawful only if, and to the extent that, at least one of the following conditions applies: (a) Consent — the data subject has given consent to the processing of his or her personal data for one or more specific purposes; (b) Contract Performance — processing is necessary for the performance of a contract to which the data subj

Article 9(1) of the UK GDPR and the EU GDPR prohibits the processing of special category data unless one of the conditions set out in Article 9(2) is met, in addition to the requirement for a lawful basis under Article 6(1). As at the date of this Policy, the NTP Group has identified 14 processing activities involving the processing of special category data. The categories of special category data processed by the NT

Article 10 of the UK GDPR and the EU GDPR imposes additional restrictions on the processing of personal data relating to criminal convictions and offences, or related security measures. The NTP Group processes criminal offence data in limited circumstances, primarily in connection with pre-employment background checks and Disclosure and Barring Service ("DBS") checks conducted in respect of employees who will have ac

6. Roles and Responsibilities 6.1 The Board of Directors The Board of Directors of Northgate Telecommunications PLC bears ultimate accountability for data protection compliance within the NTP Group. The Board is responsible for setting the strategic direction and risk appetite for data protection, for ensuring that adequate resources are allocated to the data protection function, and for overseeing the effectiveness

7. Privacy by Design and by Default 7.1 Privacy by Design

Article 25(1) of the UK GDPR and the EU GDPR requires that, both at the time of the determination of the means for processing and at the time of the processing itself, the controller shall implement appropriate technical and organisational measures designed to implement data protection principles in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of