Introduction
We hold personal data about our clients, suppliers, and other individuals for a variety of business purposes. This policy sets out how we seek to protect personal data and ensure that staff understand the rules governing their use of personal data to which they have access in the course of their work.
Who Is Responsible for This Policy?
As our Data Protection Officer, Neil Bullock has overall responsibility for the day-to-day implementation of this policy.
Our Procedures
Fair and Lawful Processing
We must process personal data fairly and lawfully in accordance with individuals' rights. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening. The exception to this is where the person is the subject of a confidential investigation.
Sensitive Personal Data
In most cases where we process sensitive personal data we will require the data subject's explicit consent, unless exceptional circumstances apply, such as the existence of a confidential investigation, or we are required to do this by law.
Accuracy and Relevance
We will ensure that any personal data we process is accurate, adequate, relevant, and not excessive, given the purpose for which it was obtained. Individuals may ask that we correct inaccurate personal data relating to them.
Data Security
You must keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented.
- Printed data is kept in a secure place and shredded when no longer needed
- Data stored on a computer is protected by strong, regularly changed passwords
- The DPO must approve any cloud service used to store data
- Servers containing personal data are kept in a secure location
- Data should never be saved directly to mobile devices such as laptops, tablets, or smartphones
Data Retention
We must retain personal data for no longer than is necessary, taking into account the reasons that the personal data was obtained.
International Data Transfers
You must not transfer personal data outside the UK without first consulting the Data Protection Officer.
Subject Access Requests
Individuals are entitled, subject to certain exceptions, to request access to information held about them. If you receive a subject access request, please contact the Data Protection Officer.
Your Rights Under GDPR
Being transparent and providing accessible information to individuals about how we use their personal data is important to our organisation. This includes the right to be informed, the right of access, the right to rectification, the right to erasure (the right to be forgotten), the right to restrict processing, the right to data portability, and the right to object.
Privacy by Design and Default
Privacy by design is an approach to projects that promotes privacy and data protection compliance from the start. The DPO is responsible for ensuring all relevant projects commence with a privacy plan.
Reporting Breaches
All members of staff have an obligation to report actual or potential data protection compliance failures. This allows us to investigate the failure, take remedial steps where necessary, and notify the Supervisory Authority of any material compliance failures.
Monitoring and Compliance
Everyone must observe this policy. The Data Protection Officer has overall responsibility for monitoring it regularly to ensure adherence.
Contact Us
Coeus Intelligence Ltd, Riverbank House, 1 Putney Bridge Approach, London SW6 3JD
admin@coeusintelligence.co.uk | +44 20 3633 8377
This policy was last reviewed in 2026 and is subject to periodic update in line with applicable data protection legislation.