Privacy Statement

Pullen Associates takes its data protection responsibilities seriously.  We support the aims of data protection legislation to strengthen the rights of individuals in respect of data relating to them and we are committed to complying with our obligations when processing personal data (either as a data controller or as a data processer).

We are ensuring compliance with our data protection obligations by:

  1. Implementing an information governance framework to manage effectively the data that we process, inclusive of personal data.

  2. Completing internal information assets audits to ensure that we fulfil our obligations in respect of the personal data we processes in light of new data protection and privacy rules being introduced in 2018 (most notably, in compliance with the EU General Data Protection Regulation (EU) 2016/679).

  3. Ensuring that personal data are processed in accordance with an appropriate lawful basis and by advising data subjects of their rights.

  4. Employing an approach that promotes and incorporates privacy and data protection considerations from the outset as well as reviewing the level of safeguards required for protecting data to ensure that appropriate organisational and technical controls are in place for the duration of the data lifecycle.

  5. Providing training and guidance to all staff in respect of their data protection responsibilities.

  6. Ensuring that the correct information governance and privacy policies are in place to support staff, notably in respect of ensuring personal data accuracy and quality, minimised data retention and adequate security policies.

  7. Ensuring that personal data are only shared where Pullen Associates is satisfied that third party recipients are legally entitled to further process it pursuant to appropriate data sharing agreements.

  8. Only working with companies for data processing services that are data protection compliant and which enter into appropriate processing agreements.

Ensuring that appropriate protection is in place for cross-border transfers of personal data, pursuant to suitable data sharing and security agreements, when Pullen Associates works with trusted organisations inside and outside the European Economic Area (EEA).

Pullen Associate’s registration number with the Information Commissioner’s Office is ZA019518