Data Protection Policy
Nexus Collections Ltd
1. Data protection principles
The Company is committed to processing data in accordance with its responsibilities under the
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate business purposes only
c. adequate, relevant and limited to what is necessary in relation to the purposes for which
they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be taken to
ensure that personal data that are inaccurate, having regard to the purposes for which
they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary
for the purposes for which the personal data are processed. Kept in a manner that
ensures appropriate security of the personal data, including protection against unauthorised
or unlawful processing and against accidental loss, destruction or damage, using
appropriate technical or organisational measures.
2. General provisions
a. This policy applies to all personal data processed by the Company.
b. The Responsible Person shall take responsibility for the Company’s ongoing compliance
with this policy.
c. This policy shall be reviewed annually.
Company means Nexus Collections Ltd
GDPR means the General Data Protection Regulation.
Responsible Person means : Howard Lawton
3. Lawful purposes
a. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in
consent shall be kept with the personal data.
b. Where communications are sent to individuals based on their consent, the option for the
individual to revoke their consent should be clearly available and systems should be in
place to ensure such revocation is reflected accurately in the Company’s systems.
4. Data minimisation
a. The Company shall ensure that personal data are adequate, relevant and limited to what
is necessary in relation to the purposes for which they are processed.
a. The Company shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put in
place to ensure that personal data is kept up to date.
6. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, the Company shall put
in place an archiving policy for each area in which personal data is processed and review
this process annually.
a. The Company shall ensure that personal data is stored securely using Flightdeck CRM
software that is kept-up-to-date.
b. Access to personal data shall be limited to personnel who need access and appropriate
security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions are in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration,
unauthorised disclosure of, or access to, personal data, the Company shall promptly assess
the risk to people’s rights and freedoms and if appropriate report this breach to the ICO
(more information on the ICO website).
END OF POLICY