GDPR & Privacy Policy 


GDPR Data Protection 

Hicktown Breakout is committed to protecting the rights and freedoms of data subjects and safely and securely processing their data in accordance with all of our legal obligations. 

We hold personal data about our employees, 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 our staff understand the rules governing their use of the personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed. 


Business purposes 

The purposes for which personal data may be used by us: 

Personnel, administrative, financial, regulatory, payroll and business development purposes. 

Business purposes include the following: 

– Compliance with our legal, regulatory and corporate governance obligations and good practice 

– Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests 

– Ensuring business policies are adhered to (such as policies covering email and internet use) 

– Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking 

– Investigating complaints 

– Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments 

– Monitoring staff conduct, disciplinary matters 

– Marketing our business 

– Improving services 


Personal data 

‘Personal data’ means any information relating to an identified or identifiable natural person (‘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, 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. 


Personal data we gather may include: individuals’ phone number, email address, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV. 

Special categories of personal data 

Special categories of data include information about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings, and genetic and biometric information —any use of special categories of personal data should be strictly controlled in accordance with this policy. 


Data controller 

‘Data controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law. 


Data processor 

‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. 



‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 


Supervisory authority 

This is the national body responsible for data protection. The supervisory authority for our organisation is [the Information Commissioners Office]. 

Who is responsible for this policy? 

As our data protection officer (DPO), Mr D Czerwionka has overall responsibility for the day-to-day implementation of this policy. You should contact the DPO for further information about this policy if necessary at 


The principles 

Hicktown Breakout shall comply with the principles of data protection (the Principles) enumerated in the EU General Data Protection Regulation. We will make every effort possible in everything we do to comply with these principles. The Principles are: 


1.Lawful, fair and transparent 

Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used. 


Limited for its purpose 

Data can only be collected for a specific purpose. 


Data minimisation 

Any data collected must be necessary and not excessive for its purpose. 



The data we hold must be accurate and kept up to date. 



We cannot store data longer than necessary. 


Integrity and confidentiality 

The data we hold must be kept safe and secure. 


Accountability and transparency 

We must ensure accountability and transparency in all our use of personal data. We must show how we comply with each Principle. You are responsible for keeping a written record of how all the data processing activities you are responsible for comply with each of the Principles. This must be kept up to date and must be approved by the DPO. 

To comply with data protection laws and the accountability and transparency Principle of GDPR, we must demonstrate compliance. You are responsible for understanding your particular responsibilities to ensure we meet the following data protection obligations: 

Fully implement all appropriate technical and organisational measures 

Maintain up to date and relevant documentation on all processing activities 


Conducting Data Protection Impact Assessments 

Implement measures to ensure privacy by design and default, including: 

Data minimisation 



Allowing individuals to monitor processing 

Creating and improving security and enhanced privacy procedures on an ongoing basis 


Our procedures 

Fair and lawful processing 

We must process personal data fairly and lawfully in accordance with individuals’ rights under the first Principle. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening. 

If we cannot apply a lawful basis (explained below), our processing does not conform to the first principle and will be unlawful. Data subjects have the right to have any data unlawfully processed erased 


Controlling vs. processing data 

Hicktown Breakout is classified as a [data controller (and/or) data processor]. We must maintain our appropriate registration with the Information Commissioners Office in order to continue lawfully [controlling (and/or) processing] data. 

As a data processor, we must comply with our contractual obligations and act only on the documented instructions of the data controller. If we at any point determine the purpose and means of processing out with the instructions of the controller, we shall be considered a data controller and therefore breach our contract with the controller and have the same liability as the controller. As a data processor, we must: 

Not use a sub-processor without written authorisation of the data controller 

Co-operate fully with the ICO or other supervisory authority 


Ensure the security of the processing 

Keep accurate records of processing activities 

Notify the controller of any personal data breaches 

If you are in any doubt about how we handle data, contact the DPO for clarification. 

Special categories of personal data 

What are special categories of personal data? 

Previously known as sensitive personal data, this means data about an individual which is more sensitive, so requires more protection. This type of data could create more significant risks to a person’s fundamental rights and freedoms, for example by putting them at risk of unlawful discrimination. The special categories include information about an individual’s: 



ethnic origin 



trade union membership 


biometrics (where used for ID purposes) 


sexual orientation 


In most cases where we process special categories of personal data we will require the data subject’s explicit consent to do this unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed. 

The condition for processing special categories of personal data must comply with the law. If we do not have a lawful basis for processing special categories of data that processing activity must cease. 



Our responsibilities 

Analysing and documenting the type of personal data we hold 

Checking procedures to ensure they cover all the rights of the individual 

Identify the lawful basis for processing data 

Ensuring consent procedures are lawful 

Implementing and reviewing procedures to detect, report and investigate personal data breaches 

Store data in safe and secure ways 

Assess the risk that could be posed to individual rights and freedoms should data be compromised 


Your responsibilities 

Fully understand your data protection obligations 

Check that any data processing activities you are dealing with comply with our policy and are justified 

Do not use data in any unlawful way 

Do not store data incorrectly, be careless with it or otherwise cause us to breach data protection laws and our policies through your actions 

Comply with this policy at all times 

Raise any concerns, notify any breaches or errors, and report anything suspicious or contradictory to this policy or our legal obligations without delay 


Responsibilities of the Data Protection Officer 

Keeping the board updated about data protection responsibilities, risks and issues 

Reviewing all data protection procedures and policies on a regular basis 

Arranging data protection training and advice for all staff members and those included in this policy 

Answering questions on data protection from staff, board members and other stakeholders 

Responding to individuals such as clients and employees who wish to know which data is being held on them by us 

Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing 


Responsibilities of the IT Manager 

Ensure all systems, services, software and equipment meet acceptable security standards 

Checking and scanning security hardware and software regularly to ensure it is functioning properly 

Researching third-party services, such as cloud services the company is considering using to store or process data 

Responsibilities of the Marketing Manager 


Approving data protection statements attached to emails and other marketing copy 

Addressing data protection queries from clients, target audiences or media outlets 

Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy 

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. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this. 


Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO. 

Data retention 


We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner consistent with our data retention guidelines. 

Transferring data internationally 


There are restrictions on international transfers of personal data. You must not transfer personal data abroad, or anywhere else outside of normal rules and procedures without express permission from the DPO. 


Rights of individuals 

Individuals have rights to their data which we must respect and comply with to the best of our ability. We must ensure individuals can exercise their rights in the following ways: 


Right to be informed 


Providing privacy notices which are concise, transparent, intelligible and easily accessible, free of charge, that are written in clear and plain language, particularly if aimed at children. 


Keeping a record of how we use personal data to demonstrate compliance with the need for accountability and transparency. 

Right of access 


Enabling individuals to access their personal data and supplementary information 

Allowing individuals to be aware of and verify the lawfulness of the processing activities 

Right to rectification 


We must rectify or amend the personal data of the individual if requested because it is inaccurate or incomplete. 

This must be done without delay, and no later than one month. This can be extended to two months with permission from the DPO. 

Right to erasure 


We must delete or remove an individual’s data if requested and there is no compelling reason for its continued processing. 

Right to restrict processing 


We must comply with any request to restrict, block, or otherwise suppress the processing of personal data. 

We are permitted to store personal data if it has been restricted, but not process it further. We must retain enough data to ensure the right to restriction is respected in the future. 


Right to data portability 

We must provide individuals with their data so that they can reuse it for their own purposes or across different services. 

We must provide it in a commonly used, machine-readable format, and send it directly to another controller if requested. 


Right to object 

We must respect the right of an individual to object to data processing based on legitimate interest or the performance of a public interest task. 

We must respect the right of an individual to object to direct marketing, including profiling. 

We must respect the right of an individual to object to processing their data for scientific and historical research and statistics. 

Rights in relation to automated decision making and profiling 

We must respect the rights of individuals in relation to automated decision making and profiling. 

Individuals retain their right to object to such automated processing, have the rationale explained to them, and request human intervention. 


Reporting breaches 

Any breach of this policy or of data protection laws must be reported as soon as practically possible. This means as soon as you have become aware of a breach. [Our organisation] has a legal obligation to report any data breaches to [name of supervisory authority] within [72 hours]. 

All members of staff have an obligation to report actual or potential data protection compliance failures. This allows us to: 

Investigate the failure and take remedial steps if necessary 

Maintain a register of compliance failures 

Notify the [name of supervisory authority] of any compliance failures that are material either in their own right or as part of a pattern of failures 

Any member of staff who fails to notify of a breach, or is found to have known or suspected a breach has occurred but has not followed the correct reporting procedures will be liable to disciplinary action. 

Please refer to our [name of reporting system] for our reporting procedure. 


Failure to comply 

We take compliance with this policy very seriously. Failure to comply puts both you and the organisation at risk. 

The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in dismissal. 

If you have any questions or concerns about anything in this policy, do not hesitate to contact the DPO.