Chief Executive Officer
Chief Executive Officer
Chief Executive Officer
Thanks to the financial support and infallible guidance of Emirates Global, which is a distinguished investment firm, we have been able to add more strategic value to our corporate relationships. Its experienced network of professionals specialise in various sectors, including business services, real estate, technology, healthcare, media, logistics, retail, oil and gas. They identify opportunities and contribute significantly to develop or improve company strategies, operations and governance through effective consultancy, technology and financial management.
During his tenure as the Chairman of Centralus, Jonathan Beckerlegge brought 26 years of experience in corporate management. He now continues to offer his expertise as part of the board.
Compliance can be easily overlooked with the heavy workloads and abundant administration associated with HR duties. So, we established a network of professional consultants that stay abreast of the latest employment law developments. Legal expertise ensures flawless business practices and peace of mind to clients on their daily tasks.
Getting a handle on your employee engagement strategy now will help you become the employer of choice tomorrow, not the former employer of yesterday.
David Callaghan
Thanks to the financial support and infallible guidance of Emirates Global, which is a distinguished investment firm, we have been able to add more strategic value to our corporate relationships. Its experienced network of professionals specialise in various sectors, including business services, real estate, technology, healthcare, media, logistics, retail, oil and gas. They identify opportunities and contribute significantly to develop or improve company strategies, operations and governance through effective consultancy, technology and financial management.
During his tenure as the Chairman of Centralus, Jonathan Beckerlegge brought 26 years of experience in corporate management. He now continues to offer his expertise as part of the board.
When auto-enrolment was introduced, managing the administrative obligations with compliance became quite challenging for employers and HR staff, who had no other choice but to sacrifice their time and resources to undertake these new responsibilities. The administrative tasks behind auto-enrolment were overwhelming and severe penalties were imposed by the Pensions Regulator for non-compliance. That’s when we took the opportunity to expand our services, relieving employers of their burdens while integrating business functions.
Compliance can be easily overlooked with the heavy workloads and abundant administration associated with HR duties. So, we established a network of professional consultants that stay abreast of the latest employment law developments. Legal expertise ensures flawless business practices and peace of mind to clients on their daily tasks.
Thanks to the financial support and infallible guidance of Emirates Global, which is a distinguished investment firm, we have been able to add more strategic value to our corporate relationships. Its experienced network of professionals specialise in various sectors, including business services, real estate, technology, healthcare, media, logistics, retail, oil and gas. They identify opportunities and contribute significantly to develop or improve company strategies, operations and governance through effective consultancy, technology and financial management.
During his tenure as the Chairman of Centralus, Jonathan Beckerlegge brought 26 years of experience in corporate management. He now continues to offer his expertise as part of the board.
When auto-enrolment was introduced, managing the administrative obligations with compliance became quite challenging for employers and HR staff, who had no other choice but to sacrifice their time and resources to undertake these new responsibilities. The administrative tasks behind auto-enrolment were overwhelming and severe penalties were imposed by the Pensions Regulator for non-compliance. That’s when we took the opportunity to expand our services, relieving employers of their burdens while integrating business functions.
Compliance can be easily overlooked with the heavy workloads and abundant administration associated with HR duties. So, we established a network of professional consultants that stay abreast of the latest employment law developments. Legal expertise ensures flawless business practices and peace of mind to clients on their daily tasks.
Getting a handle on your employee engagement strategy now will help you become the employer of choice tomorrow, not the former employer of yesterday.
David Callaghan
The employment landscape has shifted from conventional hierarchies to cross-functional management teams that foster a collaborative culture through employee engagement. As a result, Centralus proudly introduced a unique employee engagement consultancy into the UK market, shaping the future of employment by creating a workplace that fosters a purpose-driven culture aligned with every client’s mission, vision and goals. Our unique approach is specially designed for businesses that strive to gain the competitive edge.
Employees are the most valuable assets in organisations simply because they contribute their knowledge, skills and expertise. Therefore, we firmly believe that satisfying their needs will evoke commitment and loyalty while going the extra mile at work.
We empower our clients through a wide range of strategic tools, which are used to meet employment demands, supporting them on their responsibilities while creating a corporate culture where people work autonomously with enthusiasm and ultimately lead organisations to success. Our mission is to turn employee engagement into a wonderful workplace experience. David Callaghan, CEO of Centralus, is completely convinced that this is the future of employment in the UK. All employees should have access to upgraded lifestyle benefits that are key to real employee engagement.
When candidates seek job opportunities, they tend to look for something more than a standard salary. The decisive factor is the benefits package, which distinctly adds more value to a paycheque.
Desirable benefits schemes certainly help businesses attract and retain high calibre talent while employees improve their work-life balance, enhance their personal and career development, stay healthy and accumulate savings on products and services.
Fostering an engaged, productive and satisfied workforce leads to exponential growth, higher profits and superior performance.
At Centralus, we believe that the real VIPs are the employees; the people who make the effort, inspire change and instigate innovation, leading every company to success. That is why employers should treat their employees the same way they want their customers to be treated. Every customer wants to be treated like a VIP and receive exceptional services. Therefore, to make customers feel like VIPs, employers need to treat their staff the same way, and that is achieved by offering attractive benefits that satisfy employee needs.
The employment landscape has shifted from conventional hierarchies to cross-functional management teams that foster a collaborative culture through employee engagement. As a result, Centralus proudly introduced a unique employee engagement consultancy into the UK market, shaping the future of employment by creating a workplace that fosters a purpose-driven culture aligned with every client’s mission, vision and goals. Our unique approach is specially designed for businesses that strive to gain the competitive edge.
Employees are the most valuable assets in organisations simply because they contribute their knowledge, skills and expertise. Therefore, we firmly believe that satisfying their needs will evoke commitment and loyalty while going the extra mile at work.
We empower our clients through a wide range of strategic tools, which are used to meet employment demands, supporting them on their responsibilities while creating a corporate culture where people work autonomously with enthusiasm and ultimately lead organisations to success. Our mission is to turn employee engagement into a wonderful workplace experience. David Callaghan, CEO of Centralus, is completely convinced that this is the future of employment in the UK. All employees should have access to upgraded lifestyle benefits that are key to real employee engagement.
When candidates seek job opportunities, they tend to look for something more than a standard salary. The decisive factor is the benefits package, which distinctly adds more value to a paycheque.
Desirable benefits schemes certainly help businesses attract and retain high calibre talent while employees improve their work-life balance, enhance their personal and career development, stay healthy and accumulate savings on products and services.
Fostering an engaged, productive and satisfied workforce leads to exponential growth, higher profits and superior performance.
At Centralus, we believe that the real VIPs are the employees; the people who make the effort, inspire change and instigate innovation, leading every company to success. That is why employers should treat their employees the same way they want their customers to be treated. Every customer wants to be treated like a VIP and receive exceptional services. Therefore, to make customers feel like VIPs, employers need to treat their staff the same way, and that is achieved by offering attractive benefits that satisfy employee needs.
The employment landscape has shifted from conventional hierarchies to cross-functional management teams that foster a collaborative culture through employee engagement. As a result, Centralus proudly introduced a unique employee engagement consultancy into the UK market, shaping the future of employment by creating a workplace that fosters a purpose-driven culture aligned with every client’s mission, vision and goals. Our unique approach is specially designed for businesses that strive to gain the competitive edge.
Employees are the most valuable assets in organisations simply because they contribute their knowledge, skills and expertise. Therefore, we firmly believe that satisfying their needs will evoke commitment and loyalty while going the extra mile at work.
We empower our clients through a wide range of strategic tools, which are used to meet employment demands, supporting them on their responsibilities while creating a corporate culture where people work autonomously with enthusiasm and ultimately lead organisations to success. Our mission is to turn employee engagement into a wonderful workplace experience. David Callaghan, CEO of Centralus, is completely convinced that this is the future of employment in the UK. All employees should have access to upgraded lifestyle benefits that are key to real employee engagement.
When candidates seek job opportunities, they tend to look for something more than a standard salary. The decisive factor is the benefits package, which distinctly adds more value to a paycheque.
Desirable benefits schemes certainly help businesses attract and retain high calibre talent while employees improve their work-life balance, enhance their personal and career development, stay healthy and accumulate savings on products and services.
Fostering an engaged, productive and satisfied workforce leads to exponential growth, higher profits and superior performance.
At Centralus, we believe that the real VIPs are the employees; the people who make the effort, inspire change and instigate innovation, leading every company to success. That is why employers should treat their employees the same way they want their customers to be treated. Every customer wants to be treated like a VIP and receive exceptional services. Therefore, to make customers feel like VIPs, employers need to treat their staff the same way, and that is achieved by offering attractive benefits that satisfy employee needs.
Today, our suite of products and services reinforces business operations while creating employers of choice for big national clients but more so for smaller businesses and start-ups that benefit even more with us because of the economies of scale, offering them a huge advantage in a highly competitive market.
Today, our suite of products and services reinforces business operations while creating employers of choice for big national clients but more so for smaller businesses and start-ups that benefit even more with us because of the economies of scale, offering them a huge advantage in a highly competitive market.
Statement of Anti-Money Laundering (AML) and
Counter-Terrorist Financing (CTF) policies and principles
Money Laundering and Terrorist Financing have been identified as major threats to the Centralus Group and, indeed, the international financial services community. The United Kingdom, in common with many other countries, has passed legislation designed to prevent money laundering and to combat terrorism.
Legal and regulatory framework
The principal requirements, obligations and penalties, on which Centralus financial crime systems and controls are based, are contained in:
• The proceeds of Crime Act 2002 (POCA), as amended by the:
i. Serious Organized Crime and Police Act 2005 (SOCPA); and the
ii. Proceeds of Crime Act (amendment) Regulations 2007;
·.The Terrorism Act 2000, as amended by the:
i. The Anti Terrorism, Crime & Security Act 2001; and the
ii. Terrorism Act (amendment) Regulations 2007;
• The Terrorism Act 2006;
• The Bribery Act 2010;
• The Money Laundering Regulations 2007, transposing the requirements of the E.U’s third money laundering directive;
• The FCA handbook of rules and guidance, and in particular, the senior management arrangements, systems and controls (SFFISC) sourcebook, which relates to the management and control of money laundering risk; and
• The Joint Money Laundering Steering Group (JMLSG) guidance for the UK financial sector on the prevention of money laundering I combating terrorist financing.
Centralus policies & principles
Centralus is responsible for the following policies covering:
a. Anti-Money Laundering I Counter-Terrorist Financing I Counter-Proliferation Financing;
b. Training;
c. Anti-Bribery & Anti-Corruption ; and
d. Introducers.
These policies and principles are designed to ensure that all group companies comply with the legal and reg ulatory requirements applicable in the UK as well as with their local obligations.
Anti–Money Laundering (A.M.L) policy
Cer1tralus A.M.L policy is designed to ensure that comply with the requirements and obligations set out in UK legislation, regulations, rules and industry guidance for the fin ancial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate
fin ancial crime. The A.M.L policy sets out the minimum standards which must be complied with by all Centralus Group companies and includes:
• Establi shing and maintaining risk-based customer due diligence, identification, verification and know your customer (KFFIC) procedures, including enhanced due diligence for those customers presenting higher risk, such as politically exposed persons (peps) and correspondent banking relationships;
• Establishing and maintaining risk based systems and procedures to monitor ongoing customer activity;
• Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
• The maintenance of appropriate records for the minimum prescribed periods;
• Training and awareness for all relevant employees ; and
• The provision of appropriate management information and reporting to senior management of the group’s compliance with the requirements.
Training
All employees receive train ing on the Anti Money Laundering and Counter Terrorist Financing policies and principles at least once a year, with more detailed and advanced training for those whose roles involve major financial risks. Failure to comply with these policies and principles may give rise to disciplinary action, up to and including dismissal.
Anti-Bribery & Anti-Corruption policy
Centralus has a zero tolerance policy towards bribery and corruption. Centralus recognizes that bribery and corruption have an adverse effect on communities wherever they occur. If endemic, they can threaten laws, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition. Corruption is often associated with organized crime, money laundering and on occasions the financing of terrorism. In addition, the level and efficacy of investment and financing can be reduced, particularly within economically disadvantaged societies.
Centralus is committed to applying high standards of honesty and integrity consistently across our global operations and in all our business dealings. Fie are subject to the provisions of the UK bribery act 2010 and the U.S foreign corrupt practices act, which have extra-territorial effect globally, as well as applicable local anti–bribery laws in relevant jurisd ictions.
Introducers
In addition to the anti-bribery and anti-corruption policy, Centralus has an introducer clause described in the Introducer agreement. The clause covers the activities of all third parties that generate or retain business, or secure a business benefit, for Centralu s. These third parties are termed “introducers” by Centralus. Potential examples would include senior advisors, lead generators and existing clients of Centralus Group. Centralus introducer policy is designed to protect Centralus against the bribery and corruption risks, reputational risk, and wider operational and conduct risks associated with introducers. Centralus employees must apply the specific controls and procedures set out in the policy.
Centralus Group governance & conformance
Regular reviews of the effectiveness of these group policies are carried out in addition to audits periodically undertaken by Centralus internal audit function. This provides senior executive management oversight committees and the board audit committee with the necessary assurance regard ing the operating effectiveness of the group’s controls relating to these policies .
This statement is made pursuant to our company’s environmental initiatives and constitutes our group’s Environmental Policy Statement. This policy statement will be reviewed annually and published.
CENTRALUS is a fully committed member of its industry in minimising the impact of its activities on the environment.
The key points of its applied strategy in order to achieve this are:
1. Minimise waste by evaluating operations and ensuring they are as efficient as possible.
2. Minimise toxic emissions through the use of its materials and the source of its power requirements.
3. Actively promote and encourage recycling both internally, to its employees & officers, and amongst its customers and suppliers.
4. Source and promote a product range to minimise the environmental impact of both production and distribution.
5. Adopt a training programme for its personnel to raise awareness of environmental issues and enlist their support in improving the Company’s performance.
6. Meet and comply to the environmental legislation that relates to the Company.
7. Implement an accredited programme to offset the greenhouse gas emissions generated by our activities.
Where opportunities shall be identified, environmental initiatives may be extended to benefit the wider community; capturing the significance of social action and directly supporting the Company’s ethos and values.
This policy applies to all of the Company’s operations in the UK. This means that all employees, administrators, consultants, partners and businesses carried on by the Company and/or their subsidiaries, whether they are incorporated within the UK or not, must comply with it, with no exemptions.
Mission Statement
In Centralus we believe that our success is established, based on the professional and ethical behaviour of our people. Consequently, our reputation, both as individuals and as a firm, depends on it. As HR & Payroll professionals, we are responsible for adding value to the organisations we serve and contribute to their ethical success. We take on the responsibility for our individual decisions and actions. We are also advocates for the profession by engaging in activities that enhance its credibility and value.
Our clients place their trust in us and in the work that we do. So, for us, it is paramount that we follow the highest ethical standards by providing services of the highest quality; thus, creating a business environment that reflects our fundamental beliefs including continuous development and innovation, responsibility, integrity and confidentiality.
Purpose of the Code
Centralus is committed to maintaining the highest standards of ethical and professional conduct and competency in HR and recruitment. All members are encouraged to be advocates of promoting best practice within the profession and must comply with the standards set out in this Code of Conduct.
Our Code of Conduct highlights those key characteristics, which create an environment reflecting the highest professional and ethical standards.
Commitments
Actions
Professional Development
As professionals, we must seek to continually develop our professional knowledge and competence.
Commitments
Actions
Ethical Leadership
In Centralus, we believe in the need to exhibit individual leadership as a role model for maintaining the highest standards of ethical conduct.
Commitments
Actions
Fairness and Justice
As human resource professionals, we are ethically responsible for promoting and fostering fairness and justice for all employees and their organisations.
Commitments
Actions
Conflicts of Interest
As HR professionals, we must maintain a high level of trust with our stakeholders. We must protect the interests of our stakeholders as well as our professional integrity and should not engage in activities that create actual, apparent or potential conflicts of interest.
Commitments
Actions
Use of Information
We take into account and protect the rights of individuals, especially in the acquisition and distribution of information while safeguarding truthful communications and enabling informed decision-making.
Commitments
Actions
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s slavery statement. This policy statement will be reviewed annually and published.
CENTRALUS has a zero tolerance approach to any form of modern slavery and human trafficking. We are committed to acting ethically, with integrity and transparency in all business dealings and to implementing effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or our supply chain.
We are a very unique organisation that specialises in assisting companies in streamlining staff employment and payroll processing by incentivising staff through benefits and loyalty programmes whilst providing staff longevity and tax breaks.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All directors have been briefed on the subject. As part of our initiative to identify and mitigate risks we:
We expect all those in our supply chain to fully comply with our values. We use the following key performance indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
The company directors and senior management shall have the responsibility to implement this policy statement and its objectives and shall provide adequate resources and investments to ensure that slavery and human trafficking does not take place within the organisation or within its supply chains.
1.Introduction
1.1 Background to the General Data Protection Regulation (‘GDPR’)
The General Data Protection Regulation 2016 replaces the EU Data Protection Directive of 1995 and supersedes the laws of individual Member States that were developed in compliance with the Data Protection Directive 95/46/EC. Its purpose is to protect the “rights and freedoms” of natural persons (i.e. living individuals) and to ensure that personal data is not processed without their knowledge, and, wherever possible, that it is processed with their consent.
UK currently relies on the Data Protection Act 2018 that complies with the aforementioned 1995 EU Directive. It defines the law of processing data on identifiable living people and most of it does not apply to domestic use. Anyone holding personal data for other purposes is legally liable to comply with this Act, with a few notable exceptions.
1.2 Definitions
Personal data – 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.
Data controller – 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 Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Individual or Data subject – any living individual who is the subject of personal data held by an organisation.
Processing – 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.
Personal data breach – a breach of security leading to the accidental, or unlawful, destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed. There is an obligation on the controller to report personal data breaches to the supervisory authority and where the breach is likely to adversely affect the personal data or privacy of the data subject.
Consent – means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data.
Child – the GDPR defines a child as anyone under the age of 16 years old, although this may be lowered to 13 by Member State law. The processing of personal data of a child is only lawful if parental or custodian consent has been obtained. The controller shall make reasonable efforts to verify in such cases that consent is given or authorised by the holder of parental responsibility over the child.
Third party – a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Filing system – any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.
2. Data Protection Policy statement
3. Personal Information Management System & Information Security Policy (PIMS/ISP)
To support compliance with the GDPR, Centralus Board has approved and supported the development, implementation, maintenance and continual improvement of a documented PIMS, which is integrated within the ISP, for Centralus.
All Employees/Staff of Centralus and third party providers identified in the inventory are expected to comply with this policy and with the PIMS/ISP that implements this policy. All Employees/Staff will receive appropriate training.
Scope
The scope of the PIMS will cover all of the PII (Personally Identifiable Information) that the organisation holds including PII that is shared with external organisations such as suppliers, cloud providers, etc.
In determining its scope for compliance with the GDPR, Centralus considers:
The PIMS is documented within the ISP system, maintained in the Centralus Intranet. Centralus’s objectives for compliance with the GDPR are consistent with this policy, measurable, take into account GDPR privacy requirements and the results from risk assessments and risk treatments, monitored, communicated and updated as appropriate.
4. Responsibilities and roles under the General Data Protection Regulation
5. Data Protection principles
All processing of personal data must be conducted in accordance with the data protection principles as set out in Article 5 of the GDPR. Centralus’s policies and procedures are designed to ensure compliance with the principles.
Personal data must be processed lawfully, fairly and transparently
Lawfully – you must identify a lawful basis before you can process personal data. These are often referred to as the “conditions for processing”, for example, consent.
Fairly – in order for processing to be fair, the data controller has to make certain information available to the data subjects as practicable. This applies whether the personal data was obtained directly from the data subjects or from other sources.
Transparently – the GDPR includes rules on giving privacy information to data subjects in Articles 12, 13 and
14. These are detailed and specific, placing an emphasis on making privacy notices understandable and accessible. Information must be communicated to the data subject in an intelligible form using clear and plain language.
The specific information that must be provided to the data subject must, as a minimum, include:
Personal data can only be collected for specific, explicit and legitimate purposes
Data obtained for specified purposes must not be used for a purpose that differs from those formally notified to the supervisory authority as part of Centralus’s GDPR register of processing. The Privacy Procedure sets out the relevant procedures.
Personal data must be adequate, relevant and limited to what is necessary for processing
The DPO is responsible for ensuring that Centralus does not collect information that is not strictly necessary for the purpose for which it is obtained.
All data collection forms (electronic or paper-based), including data collection requirements in new information systems, must include a fair processing statement or a link to privacy statement and approved by the DPO.
The DPO will ensure that, on an annual basis all data collection methods are reviewed by internal audit to ensure that collected data continues to be adequate, relevant and not excessive.
Personal data must be accurate and kept up to date with every effort to erase or rectify without delay
Data that is stored by the data controller must be reviewed and updated as necessary. No data should be kept unless it is reasonable to assume that it is accurate. The DPO is responsible for ensuring that all staff are trained in the importance of collecting accurate data and maintaining it.
Employees/Staff/clients/contractors and third-party providers should be required to notify Centralus of any changes in circumstance to enable personal records to be updated accordingly. It is the responsibility of Centralus to ensure that any notification regarding change of circumstances is recorded and acted upon.
The DPO is responsible for ensuring that appropriate procedures and policies are in place to keep personal data accurate and up to date, taking into account the volume of data collected, the speed with which it might change and any other relevant factors.
On at least an annual basis, the DPO will review the retention dates of all the personal data processed by Centralus, by reference to the data inventory, and will identify any data that is no longer required in the context of the registered purpose. This data will be securely deleted/destroyed in line with the Information Disposal Policy.
The DPO is responsible for responding to requests for rectification from data subjects within one month. This can be extended to a further two months for complex requests. If Centralus decides not to comply with the request, the DPO must respond to the data subject to explain its reasoning and inform them of their right to complain to the supervisory authority and seek judicial remedy.
Personal data must be kept in a form such that the data subject can be identified only as long as is necessary for processing.
Where personal data is retained beyond the processing date, it will be minimised/encrypted/pseudonymised in order to protect the identity of the data subject in the event of a data breach. Personal data will be retained in line with the ISP and, once its retention date is passed, it must be securely destroyed as set out in this procedure.
The DPO must specifically approve any data retention that exceeds the retention periods defined in the ISP and must ensure that the justification is clearly identified and in line with the requirements of the data protection legislation. This approval must be written.
Personal data must be processed in a manner that ensures the appropriate security
The DPO will carry out a Data Protection Risk Assessment (DPIA) taking into account all the circumstances of Centralus’ controlling or processing operations.
In determining appropriateness, the DPO should also consider the extent of possible damage or loss that might be caused to individuals (e.g. staff or customers) if a security breach occurs, the effect of any security breach on Centralus itself, and any likely reputational damage including the possible loss of customer trust.
When assessing appropriate technical measures, the DPO shall consider the following:
When assessing appropriate organisational measures, the DPO shall consider the following:
These controls have been selected on the basis of identified risks to personal data, and the potential for damage or distress to individuals whose data is being processed. Centralus’s compliance with this principle is contained in its PIMS, which has been developed in line with the ISP.
The controller must be able to demonstrate compliance with the GDPR’s other principles (accountability)
The GDPR includes provisions that promote accountability and governance. These complement the GDPR’s transparency requirements. The accountability principle in Article 5(2) requires you to demonstrate that you comply with the principles and states explicitly that this is your responsibility.
Centralus will demonstrate compliance with the data protection principles by implementing data protection policies, adhering to codes of conduct, implementing technical and organisational measures, as well as adopting techniques such as data protection by design, DPIAs, breach notification procedures and incident response plans.
6. Personal Data individuals’ rights
Each individual shall have the following rights regarding data processing, and the data that is recorded about them:
Centralus ensures that individuals may exercise these rights by making data access requests as described in the Acceptable Use Agreement, which shall include the Subject Access Request Procedure. This procedure also describes how Centralus will ensure that its response to the data access request complies with the requirements of the GDPR.
Individuals shall also have the right to complain to Centralus related to the processing of their personal data, handling of a request from a data subject and appeals from a data subject on how complaints have been handled in line with the Complaints Procedure.
7. Consent
8. Security of Data
9. Disclosure of Data
Centralus must ensure that personal data is not disclosed to unauthorised third parties which includes family members, friends, government bodies, and in certain circumstances, the Police. All Employees/Staff should exercise caution when asked to disclose personal data held on another individual to a third party. It is important to bear in mind whether or not disclosure of the information is relevant to, and necessary for the conduct of Centralus’s business.
10. Retention and Disposal of Data
11. Data Transfers
All exports of data from within the European Economic Area (EEA) to non-European Economic Area countries (referred to in the GDPR as “third countries”) are unlawful unless there is an appropriate “level of protection for the fundamental rights of the data subjects”.
The broader area of the EEA is granted “adequacy” on the basis that all such countries are signatories to the GDPR. The non-EU EEA member countries (Liechtenstein, Norway and Iceland) apply EU regulations through a Joint Committee Decision.
Binding corporate rules
Centralus may adopt approved binding corporate rules for the transfer of data outside the EU. This requires submission to the relevant supervisory authority for approval of the rules that Centralus is seeking to rely upon.
Model contract clauses
Centralus may adopt approved model contract clauses for the transfer of data outside of the EEA. If Centralus adopts the model contract clauses approved by the relevant supervisory authority there is an automatic recognition of adequacy.
Exceptions
In the absence of an adequacy decision, Privacy Shield membership, binding corporate rules and/or model contract clauses, a transfer of personal data to a third country or international organisation shall only take place on one of the following conditions:
12. Data Inventory
Centralus has established a Data Inventory and Data Flow process as part of its approach to address risks and opportunities throughout its GDPR compliance project. Centralus’s Data Inventory and Data Flow determines:
Centralus is aware of any risks associated with the processing of particular types of personal data: