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It sets out the principles, governance structures, roles, responsibilities, and operational requirements that all Group entities, their employees, officers, directors, contractors, temporary workers, consultants, and any third party with access to NTP personal data must observe in relation to the processing of personal data

5 Related Policies and Procedures This Policy applies alongside, and must be read in conjunction with, the following NTP data protection policies and procedures, each of which is identified in greater detail in Appendix B: • Data Subject Rights Procedure • Data Breach Notification Procedure • Data Retention Schedule • International Transfers Policy & Mechanism Selection Guidance • Individual Data Protection Impact Assessment reports (DPIA-001 through DPIA-011) • ROPA Methodology & Guidance Note • Legitimate Interest Assessment Template • Privacy Notices (Consumer Subscribers, Employees, Enterprise Clients, Website) • Information Security Policy In the event of any inconsistency between this Policy and any related procedure or guidance document, the terms of this Policy shall prevail unless the related procedure or guidance document expressly states otherwise and such statement has been approved by the DPO and General Counsel

Where the NTP Group acquires additional subsidiaries, affiliates, or business units following the date of this Policy, such entities shall be brought within the scope of this Policy as part of the post-acquisition integration process, and the DPO shall be consulted in advance of any acquisition or merger to assess data protection implications and ensure timely integration

This Policy is designed to be compatible with each of these national frameworks; however, where national legislation imposes additional or more specific requirements, the relevant subsidiary must ensure compliance with those requirements in addition to the requirements of this Policy

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