Scope of data protection principles

As part of its operations, Reel Good Training Limited needs to obtain and process information. The company collects this information in a transparent way and only with the full co-operation and knowledge of interested parties. Once this information is available to the company, the following rules apply.

The company’s data shall be:
a. accurate and kept up to date;
b. collected fairly and for lawful purposes only;
c. processed by the company within its legal and moral boundaries;
d. protected against any unauthorised or illegal access by internal or external parties.

The company’s data shall not be:
a. communicated informally;
b. stored for more than a specified amount of time;
c. transferred to organisations or countries that do not have adequate data protection policies;
d. distributed to any party other than the ones agreed upon by the data’s owner (exempting legitimate requests from law enforcement bodies).

Core data protection principles

Reel Good Training Limited’s data protection policy refers to the company’s commitment to treat information of employees, customers, stakeholders and other interested parties with the utmost care and confidentiality.
With this policy, the company seeks to ensure that it gathers, stores and handles data fairly, transparently and with respect towards individual rights.
This policy refers to all parties (employees, freelance personnel, customers, suppliers etc.) who provide any amount of information to the company.
In addition, Reel Good Training Limited is committed to processing data in accordance with its responsibilities under the General Data Protection Regulation (GDPR).

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 purposes 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 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; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
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 measures.

General data provisions

This policy applies to all personal data processed by Reel Good Training Limited.
The Directors of Reel Good Training Limited shall take responsibility for the company’s ongoing compliance with this policy.
This policy shall be reviewed at least annually.

Lawful, transparent and fair processing of data

To ensure its processing of data is lawful, fair and transparent, Reel Good Training Limited shall maintain a Register of Systems.
The Register of Systems shall be reviewed at least annually.
Individuals have the right to access their personal data and any such requests made to the company shall be dealt with in a timely manner.

Accuracy of data

Reel Good Training Limited shall take reasonable steps to ensure personal data is accurate.
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.

Ensuring lawful purposes

All data processed by Reel Good Training Limited must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
Reel Good Training Limited shall note the appropriate lawful basis in the Register of Systems.
Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
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 Reel Good Training Limited’s systems.

Ensuring minimisation of data

Reel Good Training Limited shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Security provisions

Reel Good Training Limited shall ensure that personal data is stored securely using modern software that is kept up to date.
Access to personal data shall be limited to the Directors in the business. Appropriate security should be in place to avoid unauthorised sharing of information.
When personal data is deleted this should be done safely such that the data is irrecoverable.

Archiving or removal or data

To ensure that personal data is kept for no longer than necessary, Reel Good Training Limited shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
The archiving policy shall consider what data should/must be retained, for how long, and why.

Potential breaches of data

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, Reel Good Training Limited shall promptly assess the risk to people’s rights and freedoms.


Last updated: December 14, 2023