DATA PROCESSING POLICY

DATA PROCESSING POLICY

LEI Register OU (“LEI Register”) will process collected data in
accordance with the Data Protection Comissioner and Data Processing Policy. By accepting
the Terms & Conditions of LEI Register, while submitting the application,
our client thereby confirms that she/he has read Data Processing Policy and
accepts it.

Data Processing Policy

Policy prepared by: LEI Register Data
Processing Commissioner.

Introduction:

LEI Register needs to gather and use certain information about individuals and
companies. This includes information needed to apply for LEI code.
This policy describes how this personal data must be collected, handled and
stored to meet the company’s data processing standards — and to comply with the
law.

This data processing policy ensures LEI Register:

1. Complies with data protection law and follow good practice.

2. Protects the rights of staff, customers and partners.

3. Is open about how it stores and processes individuals’ data

4. Protects itself from the risks of a data breach

Data protection law

The Data Protection Act 1998
describes how organisations — including LEI Register — must collect, handle and
store personal information.
These rules apply regardless of whether data is stored electronically, on paper
or on other materials.
To comply with the law, personal information must be collected and used fairly,
stored safely and not disclosed unlawfully.
The Data Protection Act is underpinned by eight important principles. These say
that personal data must:

1. Be processed fairly and lawfully.

2. Be obtained only for specific, lawful purposes.

3. Be adequate, relevant and not excessive.

4. Be accurate and kept up to date.

5. Not be held for any longer thannecessary.

6. Processed in accordance with the rights of data subjects.

7. Be protected in appropriate ways.

8. Not be transferred outside the European Economic Area (EEA), unless that

9. Country or territory also ensures an adequate level of protection.

Policy scope

This policy applies to:

1. The head office of LEI Register.
2. All branches of LEI Register.
3. All staff and volunteers of LEI Register.
4. All contractors, suppliers and other people working on behalf of LEI Register.
5. It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998.

General staff guidelines

1. The only people able to access data covered by this policy should be those who need it for their work.

2. Data should not be shared informally. When access to confidential information is required, employees can request it
from their line managers.

3. LEI Register will provide training to all employees to help them understand their responsibilities when handling
data.

4. Employees should keep all data secure, by taking sensible precautions and following the guidelines below.

5. In particular, strong passwords must be used and they should never be shared. Personal data should not be disclosed to unauthorised people, either within the
company or externally.

6. Data should be regularly reviewed and
updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

7. Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

1. When not required, the paper or files should be kept in a locked drawer or filing cabinet.
2. Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
3. Data printouts should be shredded and disposed of securely when no longer required.
4. When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
5. Data should be protected by strong passwords that are changed regularly and never shared between employees.

6. If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
7. Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
8. Servers containing personal data should be sited in a secure location, away from general office space.
9. Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
10. Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
11. All servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to LEI Register unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

1. When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.

2. Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.

3. Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.

4. Personal data should never be transferred outside of the European Economic Area.

5. Employees should not save copies of personal data to their own computers. Always access and update the central copy
of any data.

Data accuracy

The law requires LEI Register to take
reasonable steps to ensure data is kept accurate and up to date.

1. The more important it is that the personal data is accurate, the greater the effort  should put into ensuring its accuracy.

2. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

3. Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.

4. Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.

5. LEI Register will make it easy for data subjects to update the information LEI Register holds about them. For
instance, via the company website. Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.

6. It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject access requests

All individuals who
are the subject of personal data held by LEI Register are entitled to:

1. Ask what information the company holds about them and why.

2. Ask how to gain access to it.

3. Be informed how to keep it up to date.

4. Be informed how the company is meeting its data protection obligations.

5. If an individual contacts the companyrequesting this information, this is called a subject access request.

6. Subject access requests from individuals should be made by email, addressed to the data controller at [email protected] The data controller can supply a standard request form, although individuals do not have to use this. Individuals will be charged 10€ per subject access request. The data controller will aim to provide the relevant data within 14 days.

7. The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

1. LEI Register will provide information
fo GLEIF and its registered LOU-s who are also entitled to process customer
data according to LEI Register’s Data Processing Policy.

2. In certain circumstances, the Data
Processing Policy allows personal data to be disclosed to law enforcement
agencies without the consent of the data subject.

Under these circumstances, LEI Register will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.