Privacy Policy

Senaryo Services Ltd

Reg No: 12080271

1. Scope, Purpose and Users

Senaryo Services Ltd   strives to comply with all applicable laws and regulations related to personal data protection in countries where Senaryo Services operates. This policy sets forth the basic principles by which Senaryo Services processes the personal data of consumers, customers, suppliers, business partners, employees and other individuals, and indicates the responsibilities of its business departments and employees while processing personal data.

This Policy applies to Senaryo Services and its third parties processing the personal data of data subjects within EEA.

The users of this document are all employees (permanent or temporary) and all contractors working on behalf of Senaryo Services.


2. Reference Documents

·    EU GDPR 2016/679 (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC);

·        Data Protection Act 2018 (DPA 2018);


3. Definitions

The following definitions of terms used in this document are drawn from Article 4 of the European Union’s General Data Protection Regulation:

Personal Data: Any information relating to an identified or identifiable natural person ("Data Subject") 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.

Sensitive Personal Data: Personal data which are, by their nature, particularly sensitive in relation to fundamental rights and freedoms merit specific protection as the context of their processing could create significant risks to the fundamental rights and freedoms. Those personal data include personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Data Controller: The natural or legal person, public authority, agency or any other body, which alone or jointly with others, determines the purposes and means of the processing of personal data.

Data Processor: A natural or legal person, public authority, agency or any other body which processes personal data on behalf of a Data Controller.

Processing: An 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 of the data.

Anonymisation: Irreversibly de-identifying personal data such that the person cannot be identified by using reasonable time, cost, and technology either by the controller or by any other person to identify that individual. The personal data processing principles do not apply to anonymized data as it is no longer personal data.

Pseudonymisation: The processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person. Pseudonymisation reduces, but does not completely eliminate, the ability to link personal data to a data subject. Because pseudonymised data is still personal data, the processing of pseudonymised data should comply with the Personal Data Processing principles.

Cross-border processing of personal data: Processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the European Union where the controller or processor is established in more than one Member State; or processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State;

Supervisory Authority: An independent public authority which is established by a Member State pursuant to Article 51 of the EU GDPR;

Lead supervisory authority: The supervisory authority with the primary responsibility for dealing with a cross-border data processing activity, for example when a data subject makes a complaint about the processing of his or her personal data; it is responsible, among others, for receiving the data breach notifications, to be notified on risky processing activity and will have full authority as regards to its duties to ensure compliance with the provisions of the EU GDPR;

Each “local supervisory authority” will still maintain in its own territory and will monitor any local data processing that affects data subjects or that is carried out by an EU or non-EU controller or processor when their processing targets data subjects residing on its territory. Their tasks and powers include conducting investigations and applying administrative measures and fines, promoting public awareness of the risks, rules, security, and rights in relation to the processing of personal data, as well as obtaining access to any premises of the controller and the processor, including any data processing equipment and means.

“Main establishment as regards a controller” with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered to be the main establishment;

“Main establishment as regards a processor” with establishments in more than one Member State, the place of its central administration in the Union, or, if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place to the extent that the processor is subject to specific obligations under this Regulation;

Group Undertaking: Any holding Company together with its subsidiary.


4. Basic Principles Regarding Personal Data Processing

The data protection principles outline the basic responsibilities for organisations handling personal data. Article 5(2) of the GDPR stipulates that “the controller shall be responsible for, and be able to demonstrate, compliance with the principles.”

4.1 Lawfulness, Fairness and Transparency

We will only process personal data where we have one of the following ‘lawful bases’ (legal reasons) to do so under data protection law:

·         fulfil a contract with the individual, or the individual has asked Senaryo Services to take specific steps before entering into a contract.

·         comply with a legal obligation.

·         legitimate interests of Senaryo Services or a third party (provided the individual’s rights and freedoms are not overridden).

·         consent.

4.2 Purpose Limitation

We will only collect personal data for specified, explicit and legitimate reasons. We explain these reasons to the individuals when we first collect their data.

If we want to use personal data for reasons other than those given when we first obtained it, we will inform the individuals concerned before we do so and seek consent where necessary.

Staff will only process personal data where it is necessary in order to do their jobs. When staff no longer need the personal data they hold, they will ensure it is deleted or anonymised. This will be done in accordance with Senaryo Services record retention schedule/records management policy.

4.3 Data Minimisation

All Personal data processed is adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.  Senaryo Services may apply anonymization or pseudonymisation to personal data, if possible, to reduce the risks to the data subjects concerned.

4.4 Accuracy

All Personal data processed is accurate and, where necessary, kept up to date; reasonable steps are taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified in a timely manner.

4.5 Storage Period Limitation

Personal data will be kept for no longer than is necessary for the purposes for which the personal data is processed.

4.6 Integrity and confidentiality

Taking into account the state of technology and other available security measures, the implementation cost, and likelihood and severity of personal data risks, Senaryo Services applies appropriate technical and organisational measures to process Personal Data in a manner that ensures appropriate security of personal data, including protection against accidental or unlawful destruction, loss, alternation, unauthorized access to, or disclosure.

We will put measures in place to show that we have integrated data protection into all of our data processing activities, including:

·     Only processing personal data that is necessary for each specific purpose of processing, and always in line with the data protection principles set out in relevant data protection law.

·         Completing privacy impact assessments where Senaryo Services processing of personal data presents a high risk to rights and freedoms of individuals, and when introducing new technologies.

·         Integrating data protection into internal documents including this policy, any related policies and privacy notices

·       Regularly training members of staff on data protection law, this policy, any related policies and any other data protection matters; we will also keep a record of attendance.

·         Regularly training members of staff on data protection law, this policy, any related policies and any other data protection matters; we will also keep a record of attendance.

·         Regularly conducting reviews and audits to test our privacy measures and make sure we are compliant.

o       For the benefit of data subjects, making available the name and contact details of Senaryo Services and all information we are required to share about how we use and process their personal data.

o     For all personal data that we hold, maintaining an internal record of the type of data, data subject, how and why we are using the data, any third-party recipients, how and why we are storing the data, retention periods and how we are keeping the data secure.


4.7 Accountability

 Senaryo Services as a Data controller is responsible for and is able to demonstrate compliance with the principles outlined above.


5. Building Data Protection in Business Activities

In order to demonstrate compliance with the principles of data protection, Senaryo Services has built data protection into its business activities.

5.1 Notification to Data Subjects

(See Section 6 - Fair Processing Guidelines.)

5.2 Data Subject’s Choice and Consent

(See Section 6 - Fair Processing Guidelines.)

5.3 Collection

 Senaryo Services strives to collect the least amount of personal data possible. If personal data is collected from a third party, Senaryo Services will ensure that the personal data is collected lawfully. We collect and use your personal data to administer our relationship with you, including to respond to your enquiries or complaints, to provide our products and Services to you, to manage our Contracts with you, to inform you about our products and services, partners, promotions and events, to administer and improve our Websites and Services, to respond to requests from authorities, to comply with our contractual and legal obligations, and for other legitimate business purposes.  Senaryo Services does not share, sell, rent or trade personal data with third parties for promotional purposes.

When you express an interest in obtaining additional information about the Services or registering for an event, you provide  Senaryo Services with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”) to contact you. In addition, when you purchase the Services or get registered for an event,  may also require you to provide  Senaryo Services with means for financial qualification and billing information, such as billing name and address, and the number of employees within the organization that will be using the Services (“Billing Information”) which is not considered personal data.

We may ask you for information to enable us to provide a Service to you and we collect this information by telephone, written/digital correspondence or via the website. Subject to your consent where required by law, we use cookies and other technologies to track the use of our websites and services.

Subject to your consent where required by law, we may use your personal data to conduct marketing, promotional and informational activities and to perform business analytics, satisfaction surveys or market research and conduct direct marketing.

We may share your personal data with third party providers that we engage to process data on our behalf, when such sharing is required by law or other situations as permitted by law. In accordance with applicable law, you have the right to access personal data we hold about you, to rectify, delete or erase inaccurate data, to object, at any time and free of charge, to the processing of your personal data for direct marketing purposes, as well other rights under applicable law.


5.4 Use, Retention, and Disposal

 Senaryo Services will maintain the accuracy, integrity, confidentiality and relevance of personal data based on the processing purpose. Adequate security mechanisms designed to protect personal data are used to prevent personal data from being stolen, misused, or abused, and prevent personal data breaches.

We will protect personal data and keep it safe from unauthorised or unlawful access, alteration, processing or disclosure, and against accidental or unlawful loss, destruction or damage. In particular:

·        Paper-based records and portable electronic devices, such as laptops and hard drives that contain personal data are kept under lock and key when not in use.

·      Papers containing confidential personal data must not be left on office desks, on staffroom tables, pinned to notice/display boards, or left anywhere else where there is general access.

·        Passwords that are at least 8 characters long containing letters and numbers are used to access Senaryo Services computers, laptops and other electronic devices. Staff are reminded to change their passwords at regular intervals.

·    Staff, who store personal information on their personal devices are expected to follow the same security procedures as for Senaryo Services owned equipment.

·      Where we need to share personal data with a third party, we carry out due diligence and take reasonable steps to ensure it is stored securely and adequately protected (see section 5.5)

5.5 Disclosure to Third Parties

Whenever Senaryo Services uses a third-party supplier or business partner to process personal data on its behalf, it will ensure that this processor will provide security measures to safeguard personal data that are appropriate to the associated risks. For this purpose, the Processor GDPR Compliance Questionnaire will be used. We will establish a data sharing agreement with the supplier or contractor, to ensure the fair and lawful processing of any personal data we share.

 Senaryo Services will contractually require the supplier or business partner to provide the same level of data protection as Senaryo Services provides. The supplier or business partner must only process personal data to carry out its contractual obligations towards Senaryo Services or upon the instructions of Senaryo Services and not for any other purposes. When Senaryo Services processes personal data jointly with an independent third party, Senaryo Services will explicitly specify its respective responsibilities of and the third party in the relevant contract or any other legal binding document, such as the Supplier Data Processing Agreement.

A list of such partners could be provided to Customers upon request provided there is a legitimate reason.

5.6 Cross-border Transfer of Personal Data

Before transferring personal data out of the European Economic Area (EEA) adequate safeguards will be used including the signing of a Data Transfer Agreement, as required by the European Union and, if required, authorisation from the relevant Data Protection Authority will be obtained.

5.7 Rights of Access by Data Subjects

Acting as a data controller, Senaryo Services is responsible for providing data subjects with a reasonable access mechanism to enable them to access their personal data, and it allows them to update, rectify, erase, or transmit their Personal Data, if appropriate or required by law.

Individuals have a right to make a “data subject access request” to gain access to personal information that Senaryo Services holds about them. This includes:

Confirmation that their personal data is being processed

·         Access to a copy of the data

·          The purposes of the data processing

·         The categories of personal data concerned

·           Who the data has been, or will be, shared with

·         How long the data will be stored for, or if this isn’t possible, the criteria used to determine this period

·         The source of the data, if not the individual

·         Whether any automated decision-making is being applied to their data, and what the significance and consequences of this might be for the individual

Subject access requests should include:

·          Name of individual

·         Correspondence address

·         Contact number and email address

·          Details of the information requested

A data subject access request form will be sent to the individual.

5.8 Data Portability

Data Subjects have the right to receive, upon request, a copy of the data they provided to us in a structured format and to transmit those data to another controller, for free.

5.9 Right to be Forgotten

Under certain circumstances, data subjects have the right to request from Senaryo Services, the erasure of their personal data. When Senaryo Services is acting as a Controller, it will take necessary actions (including technical measures) to inform the third parties who use or process that data to comply with the request.


6. Fair Processing Guidelines

 Senaryo Services will decide whether to perform the Data Protection Impact Assessment for each data processing activity.

6.1 Notices to Data Subjects

At the time of collection or before collecting personal data  for any kind of processing activities including but not limited to selling products, services, or marketing activities,  Senaryo Services must properly inform data subjects of the following: the types of personal data collected, the purposes of the processing, processing methods, the data subjects’ rights with respect to their personal data, the retention period, potential international data transfers, if data will be shared with third parties and  Senaryo Services’ security measures to protect personal data.

6.2 Obtaining Consent

Whenever personal data processing is based on the data subject's consent, Senaryo Services is responsible for retaining a record of such consent.   Senaryo Services is responsible for providing data subjects with options to provide the consent and must inform and ensure that their consent can be withdrawn at any time.

When requests to correct, amend or destroy personal data records, Senaryo Services will ensure that these requests are handled within a reasonable time frame.  Senaryo Services will also record the requests and keep a log of these.

Personal data will only be processed for the purpose(s) for which they were originally collected. In the event that Senaryo Services wants to process collected personal data for another purpose, Senaryo Services will seek the consent of its data subjects in clear and concise writing. Any such request will include the original purpose for which data was collected, and the new, or additional, purpose(s). The request will also include the reason for the change in purpose(s).

 Senaryo Services is responsible for creating and maintaining a Register of the General Data Protection Notices.


7. Response to Personal Data Breach Incidents

When Senaryo Services learns of a suspected or actual personal data breach, it must perform an internal investigation and take appropriate remedial measures in a timely manner. Where there is any risk to the rights and freedoms of data subjects, Senaryo Services must notify the relevant data protection authorities without undue delay and, when possible, within 72 hours.

When the personal data breach or suspected data breach affects personal data that is being processed by Senaryo Services as a data controller, the following actions are performed:

·         Senaryo Services must establish whether the personal data breach should be reported to the Supervisory Authority.

·        In order to establish the risk to the rights and freedoms of the data subject affected, Senaryo Services must perform the Data Protection Impact Assessment on the processing activity affected by the data breach.

·      If the personal data breach is not likely to result in a risk to the rights and freedoms of the affected data subjects, no notification is required. However, the data breach should be recorded.

·      The Supervisory Authority must be notified with undue delay but no later than in 72 hours, if the personal data breach is likely to result in a risk to the rights and freedoms of the data subjects affected by the personal data breach. Any possible reasons for delay beyond 72 hours must be communicated to the Supervisory Authority.

 Senaryo Services will send Notifications to the Supervisory Authority that will include the following:

  • A description of the nature of the breach

  • Categories of personal data affected

  • Approximate number of data subjects affected

  • Consequences of the personal data breach

  • Measures taken to address the personal data breach

  • Any information relating to the data breach


8. Conflicts of Law

This Policy is intended to comply with the laws and regulations in the place of establishment and of the countries in which ACME operates. In the event of any conflict between this Policy and applicable laws and regulations, the latter shall prevail.


9. Validity and Document Management

This document is valid as of 2nd November 2020.


Ian Bennett

Senaryo Services Ltd