Data Protection

EURO PRO FOOTBALL LTD will need to obtain certain information from you.
We take data protection compliance very seriously. Failure to comply puts both individuals and the organisation at risk.
Our policy (see below) sets out how we assure you that we will always keep your data safe and private. We will never
sell your data, and we allow you to review and change your marketing choices at any time.

Policy Statement

We hold personal data about our employees, clients, suppliers and other individuals for a variety of business purposes.
This policy sets out how we seek to protect that data and ensure that staff understand the rules governing their use of
personal data to which they have access during the course of their work.
This policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any new or significant
changes to data processing activity is initiated. This could be internally driven I.E. operational changes or externally
driven e.g. legislative or adopted standard changes.

This policy is designed to ensure and evidence our adherence to the current applicable data protection legislation.
Namely: Data Protection Act 2018 and General Data Protection Regulations.

Scope

EURO PRO FOOTBALL is a business registered, operating and processing data within the UK, with under 50 employees.
This policy applies to all who we hold personal data on for business purposes.
All EURO PRO FOOTBALL staff must be familiar with this policy. This policy is displayed internally for ongoing
awareness and transparency.
Given the broad scope of data protection, this policy supplements our Company Handbooks and Terms of Business. As
well as our other policies and processes relating to IT Security, Data Management, Incident Control, Internet and
Electronic Mail Use and our Supplier Code of Conduct.

Objective(s)

The processing of all data must be:
Necessary to deliver our services.
In our legitimate interests and not unduly prejudice the individual’s privacy.
In most cases this provision will apply to routine business data processing activities.
Our procedures must reflect fair and lawful processing; therefore, we must process personal data fairly and lawfully in
accordance with individuals’ rights. This generally means that we should not process personal data unless the individual
whose details we are processing has consented to this happening, while maintaining obvious and clear methods for optout or un-subscription

Key Responsibilities

The board of Directors have overall responsibility for data protection.
The CEO (Carlo Di Manno) is our designated Data Protection Officer (DPO) and has overall responsibility for the day-today implementation of this policy

Data Protection Specifics

IT Systems & Arrangements
Ensure all systems, services, software and equipment meet acceptable security standards.
Checking and scanning security hardware and software regularly to ensure it is functioning properly.
Researching third-party services, such as cloud services the company is considering using to store or process data.
Sales & Marketing Management
Approving data protection statements attached to other marketing copy.
Addressing data protection queries from clients, target audiences or media outlets.
Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data
Protection Policy

Terms of Business

Our Terms of Business contains a Data Protection Notice to clients highlighting our data protection commitment and
legislative compliance. A copy of this policy can be provided to supplement those Terms of Business, upon request.

Human Resources

Sensitive Personal Data (EURO PRO FOOTBALL Staff primarily only) In most cases where we process sensitive personal
data we will require the data subject’s explicit consent to do this unless exceptional circumstances apply or we are
required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent
will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.
Personal data: We will take all reasonable steps to ensure that personal data we hold is accurate and updated as
required.

Accuracy and Relevance

We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose
for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose
unless the individual concerned has agreed to this or would otherwise reasonably expect this.
Individuals may ask that we correct inaccurate personal data relating to them. If they believe that information is
inaccurate, we will record the fact that the accuracy of the information is disputed and inform the DPO.

Data Security & Storage

All applicable staff must keep personal data secure against loss or misuse. Where other organisations process personal
data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need
to be implemented in contracts with those third-party organisations.

Storing Data Securely

In cases when data is stored on printed paper, it should be kept in a secure place where unauthorised personnel cannot
access it.
Printed data is to be securely shredded when it is no longer needed.
Data stored on a computer should be protected by strong passwords that are force changed regularly.
Data stored on CDs or memory sticks must be locked away securely when they are not being used.
The DPO must approve any cloud used to store data.
Servers containing personal data are kept in a secure location, away from general office space.
Data is regularly backed up in line with the company’s existing backup procedures.
Data is to never be saved directly to PC desktops, mobile devices such as laptops, tablets or smartphones.
All servers containing sensitive data are protected by security software and a strong firewall.

Data Retention

We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of
each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner
consistent with our data retention guidelines.

Subject Access Requests & Individuals Rights

Individuals are entitled by law, subject to certain exceptions or restrictions, to request access to information held about
them. If we do receive a subject access request, it will be referred immediately to the DPO. Response will be issued on
an as soon as possible basis, under authorisation of the CEO. This response will be issued no later than one calendar
month from the initial request.
Staff should contact the DPO if they would like to correct or request information that we hold about you.
With regards to the processing of personal data, we will abide by any request from an individual not to use their
personal data for direct marketing purposes and notify the DPO about any such request.
We do not send direct marketing material to someone electronically (IE via email) unless they are deemed to have a
genuine interest i.e., we have an existing enquiry or business relationship with them, in relation to the products or
services being marketed.
The DPO should be consulted for advice on direct marketing before starting any new direct marketing activity.
Escalating to the CEO, where appropriate.

Training

All staff receive training on this policy. New joiners will receive training as part of the induction process. Further training
will be provided periodically or whenever there is a substantial change in the law or our policy and procedure.
Completion of training is compulsory.
Training is provided through an in-house awareness seminar, which covers:
· The law relating to data protection.
· Our data protection and related policies and procedures

Data Protection Act 2018 (GDPR) Specific Provisions

In consideration to the above legislation, where not specified previously within this policy, the following provisions were
in effect on or before 25th May 2018.

Privacy Notice (Transparency of Data Protection)

Being transparent and providing accessible information to individuals about how we use their personal data is important
for our organisation. We have a process that details on how we collect data and what we will do with it for any persons
interested.

Conditions for Processing

We ensure any use of personal data is justified using at least one of the conditions for processing and this will be
specifically documented. All staff who are responsible for processing personal data are aware of the conditions for
processing. The conditions for processing will be available to data subjects in the form of a privacy notice.

Justification for Personal Data

We process personal data in compliance with all ‘relevant’ six data protection principles. We will document the
additional justification for the processing of sensitive data and will ensure any biometric and genetic data is considered
sensitive.

Consent

The data that we collect is subject to active consent by the data subject. This consent can be revoked at any time, in
writing or through unsubscribe mechanisms.

Data Portability

Upon request, a data subject should have the right to receive a copy of their data in a structured format. These requests
should be processed within one month, provided there is no undue burden and it does not compromise the privacy of
other individuals. A data subject may also request that their data is transferred directly to another system. This must be
facilitated free of charge.

Right to be Forgotten

A data subject may request that any information held on them is deleted or removed, and any third parties who process
or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.

Privacy by Design and Default

Privacy by design is an approach to projects that promote privacy and data protection compliance from the start. The
DPO will be responsible for conducting Privacy Impact Assessments as well as ensuring that all data protection
applicable projects commence I.E. IT, commence with a Privacy Plan.
When relevant, and when it does not have a negative impact on the data subject, privacy settings will be set to the most
private by default.

Data Audit and Register

Regular data audits to manage and mitigate risks will inform the data register. We have a register detailing information
on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention
timescales that may be relevant.

Reporting Breaches

All members of staff have an obligation to report any actual or potential data protection compliance failures (data
breach). This will be reported to the DPO, investigated and handled as an Internal Non-Conformance. This allows us to:
Investigate the failure and take remedial steps if necessary,Maintain a register of compliance failures, Notify the DPO
ideally within 24 hours, but within an absolute maximum of 72 hours, of any compliance failures that are a material
breach either in their own right or as part of a pattern of failures.

Your Rights

You have the right to ask us not to process your personal data for our own, internal marketing purposes. We will usually
inform you before collecting your data if we intend it for such purposes and you can exercise your right to prevent such
processing by indicating your choice in the boxes on the forms we use to collect your data. You can also ask us not to
process your personal data for our own marketing purposes at any time by writing to us at info@euprofootball.com
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and
affiliates. If you follow a link to any of these websites, please note that these websites have their own data protection
policies and that we do not accept any responsibility or liability for these policies. Please check these policies before
you submit any personal data to these websites.
Under the Data Protection Act you have the right to request to see what information we hold about you. Any requests
to see such information should be made in writing to info@euprofootball.com and will usually be free of charge, unless
the request is manifestly unfounded or excessive, or is a duplicate request, in which case a small fee may be charged to
cover our costs in providing you with this information.
If you have any concerns, you also have the right to make a complaint at any time to the Information Commissioner’s
Office (ICO) ico.org. However, we would appreciate the opportunity to deal with your concerns first by contacting
info@euprofootball.com

Monitoring

Everyone throughout the company must observe and abide by this policy. The DPO will monitor and review the policy
periodically to ensure compliance.
This policy statement will be reviewed for continuing suitability annually.
Carlo Paolo Di Manno
Founder/CEO