Data Protection Principles
Clear Fr8 Midlands is committed to processing data in accordance with its responsibilities
under the General Data Protection Regulation.
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 purposed and not further processed in
a manner that is incompatible with those purposes: further processing for archiving
purposes in the public interest, scientific or historical research purposes or statistical
purposes shall not be considered to be incompatible with the initial purposes;
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 take
to ensure that personal data that are inaccurate, having regard to the purposes for
which the personal data are processed;
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;
f) Processed 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
General Provisions
a) This policy applies to all personal data processed by Clear Fr8 Limited.
b) The responsible person shall take responsibility for Clear Fr8 Limited’s ongoing
compliance with this policy.
c) This policy shall be reviewed at least annually.
d) Clear Fr8 Midlands shall register with the Information Commissioner’s office as an organisation
that processes personal data.
Lawful, Fair and Transparent Processing
a) To ensure its processing of data is lawful, fair and transparent, Clear Fr8 Midlands shall
maintain a Register of Systems.
b) The Register of Systems shall be reviewed at least annually.
c) Individuals have the right to access their personal data and any such requests made
to Clear Fr8 Midlands shall be dealt with in a timely manner.
Lawful Purposes
a) All data processed by the charity must be done on one of the following lawful bases;
consent, contract, legal obligation, vital interests, public task or legitimate interests.


b) Where consent is relied upon as a lawful process for processing data, evidence of
opt-in consent shall be kept with the personal data.
c) 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 Charity’s systems.
Data Minimisation
a) Clear Fr8 Midlands shall ensure the personal data is adequate, relevant and limited to
what is necessary in relation to the purposes for which they are processed.
a) Clear Fr8 Midlands 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.
Archiving / Removal
a) To ensure that personal data is kept for no longer than necessary, the charity shall
put in place an archiving policy for each area in which personal data is processed and
review this process annually.
b) The archiving policy shall consider what data should/must be retained, for how long,
and why.
a) Clear Fr8 Midlands shall ensure that personal data is store securely using modern
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
d) Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to an accidental or unlawful destruction, loss,
alteration, unauthorised disclosure of, or access to, personal date, Clear Fr8 Midlands shall promptly
assess the risk to people’s rights and freedoms and if appropriate report this breach to the