Appendix A: GDPR Data Subject Rights

When applicable, you (the Data Subject) have the following rights regarding the processing of your personal information under General Data Protection Regulation (EU Regulation 2016/679, Chapter 3, Articles 12-23. These rights are summarised here. For a more detailed explanation, ‘s please refer to the UK’s Information Commissioner’s website.

1. The Right to Access: You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to £15 fee.
2. The Right to Rectification: You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
3. The Right to Erasure: In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw consent to consent-based processing
• you object to the processing under certain rules of applicable data protection law
• the processing is for direct marketing purposes, and
• the personal data have been unlawfully processed.

However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary (for exercising the right of freedom of expression and information, for compliance with a legal obligation, or for the establishment, exercise or defense of legal claims).

4. The Right to Restrict Processing: In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are:

• you contest the accuracy of the personal data
• processing is unlawful, but you oppose erasure
• we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims
• you have objected to processing, pending the verification of that objection.

Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

5. The Right to Object to Processing: You have the right to object to our processing of your personal data on grounds relating to your situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:

• the performance of a task carried out in the public interest or in the exercise of any official authority vested in us;
• or the purposes of the legitimate interests pursued by us or by a third party.

If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

6. The Right to Data Portability: To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or

(b)    that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7. The Right to Complain to a Supervisory Authority: If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the ICO.
8. The Right to Withdraw Consent: To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.