Fishawack Group of Companies: Privacy and Data Protection Policy

During the course of our activities, the Fishawack Group of Companies (“Fishawack”) collects, stores and processes personal information about our staff, customers, suppliers and other third parties such as Names, contact details and in some circumstances, financial details. We recognise the need to treat personal data in appropriate fair, lawful and transparent manner, in accordance with prevailing UK and other relevant international Data Protection law. In the UK, our business entities are registered with the Information Commissioner’s Office and are listed as a data controller for defined purposes.

  • Fishawack Group Limited (registration number: ZA267403)
  • Fishawack Communications Limited (registration number: Z5586262)
  • Fishawack Facilitate Limited (registration number: Z672068X)
  • Fishawack Indicia Limited (registration number: ZA267398)

This document is a statement of the data protection policy adopted by Fishawack. All staff must be familiar with and apply this policy, and seek further advice if in doubt as to its application or otherwise when required. This policy applies to treatment of personal data and sensitive personal data.

“Personal data” means any data relating to a living individual who can be identified from that data (or from that data and other information in our possession). From implementation of the General Data Protection Regulation (“GDPR”) on 25 May 2018, this will include direct and indirect identification and identification by all means reasonably likely to be used. Personal data can therefore be factual (such as a name, address or date of birth) or it can be an opinion. It can also mean location data and online identifiers such as cookies and IP addresses). Such personal information must be dealt with properly however it is collected, recorded and used – whether on paper, electronically, or by other means.

“Sensitive personal data” includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition, or about the commission of, any offence committed or alleged to have been committed by that person. Sensitive personal data can only be processed under strict conditions. Under the GDPR, sensitive personal data will be redefined as “Special Categories of Data” and will include genetic and biometric data, but will not extend to the commissioning of any committed or alleged offence (these will be given separate protections).

Fishawack needs to collect and use certain personal and sensitive personal data relating to the individuals with whom it deals in order to operate. These include current, past and prospective parties such as employees, suppliers, clients and their external contacts e.g. the healthcare community.

Fishawack regards the lawful and correct treatment of personal data and sensitive personal data as important to the achievement of our objectives, to the success of our operations and to maintaining confidence between those with whom we deal and ourselves. We therefore ensure that our organisation treats personal information fairly, lawfully and transparently. To this end Fishawack fully endorses and adheres to the 8 Data Protection Principles, as set out in the Data Protection Act 1998 (“the Act”) and equivalent principles laid out in the General Data Protection Regulation. These principles must be adhered to by anyone who processes personal data. “Processing” is any activity that involves use of the data, such as obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties and other countries both inside and outside of the European Economic Area.

Fishawack will adhere to these principles when obtaining, handling, processing, transporting and storing personal data.

Specifically, the principles we must abide by require that personal information:

  1. shall be processed fairly, lawfully and transparently and, in particular, shall not be processed unless specific conditions (as set out in the law) are met;
  2. shall be obtained only for one or more specified, explicit and legitimate purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes;
  3. shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed;
  4. shall be accurate and, where necessary, kept up to date;
  5. shall not be kept for longer than is necessary for that purpose or those purposes;
  6. shall be processed in accordance with the rights of data subjects under the Act;
  7. shall be subject to appropriate technical and organisational measures to prevent the unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data; and
  8. shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

Fishawack will comply with the accountability requirement in article 5(2) of the GDPR and will demonstrate compliance with the above principles.

In addition, Fishawack will, through appropriate management, strict application of criteria and controls, comply with the principles of data protection by design and default. This will include ensuring that Fishawack:

  • observes fully the conditions regarding the fair and transparent collection and use of information. This means that the data subject (i.e. the individual to whom the personal data relates) must be told who the data controller is (in this case, Fishawack), the purpose for which the data is to be processed, and the identities of anyone to whom the data may be disclosed or transferred. For personal data to be processed fairly, lawfully and transparently, certain conditions have to be met. These may include, among other things, requirements that the data subject has consented to the processing, or that the processing is necessary for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive personal data is being processed, more than one condition must be met. In most cases the data subject's explicit consent to the processing of sensitive personal data will be required, although there are other conditions which may lawfully be used;
  • meets its legal obligations to specify the purposes for which information is used. This means that personal data will not be collected for one purpose and then used for another. If it becomes necessary to change the purpose for which the data is processed, the data subject will be informed of the new purpose before any processing occurs;
  • collects and processes appropriate information, and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements. Any data which is not necessary for the relevant purpose will not be collected in the first place;
  • ensures the quality and accuracy of information used. Information which is incorrect or misleading is not accurate and steps will therefore be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out-of date data will be destroyed or rectified at the earliest opportunity;
  • applies strict checks to determine the length of time information is held. Data will be destroyed or erased from our systems when it is no longer required;
  • ensures that data is processed in accordance with data subjects’ rights under the Act and other prevailing data protection legislation. These include: the right to be informed that processing is being undertaken, the right of access to one’s personal information, the right to prevent processing in certain circumstances and the right to correct, rectify, block or erase information which is regarded as wrong information;
  • puts in place appropriate technical and organisational security measures to safeguard personal data from the point of collection to the point of destruction;
  • ensures that personal information is not transferred abroad without suitable safeguards in accordance with the Act and other prevailing data protection legislation;
  • treats people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information ; and
  • sets out clear procedures for responding to requests for information from third parties. When dealing with enquiries from third parties, Fishawack will take steps before disclosing any personal information held by us to ensure that this is done in accordance with permissive provisions in the legislation or applicable exemptions. In particular we will:
    1. check the identity of the person making the enquiry and whether they are legally entitled to receive the information they have requested;
    2. require that the third party put their request in writing so the third party's identity and entitlement to the information may be verified;
    3. refer requests to our Data Protection Officer for assistance in difficult situations; and
    4. where providing information to a third party, do so in accordance with the law.

In addition, Fishawack will ensure that:

  1. there is always someone with specific responsibility for and knowledge of data protection who will act as the internal and external point of contact, handle complaints from data subjects and report to the business on data protection risk;
  2. everyone handling personal information understands that they are contractually responsible for following good data protection practice;
  3. everyone handling personal information is appropriately trained to do so and that this training is refreshed at suitable intervals;
  4. everyone handling personal information is appropriately supervised;
  5. anybody wanting to make enquiries about handling personal information knows what to do and who to refer enquiries to;
  6. queries about handling personal information are promptly and courteously dealt with;
  7. methods of handling personal information are clearly described;
  8. a regular review and audit is made of the way personal information is held, managed and used, including where new categories of personal data are processed or where processing takes place or if processing is deemed to present a risk to the rights and freedoms of individuals;
  9. appropriate records of processing records are maintained;
  10. methods of handling personal information are regularly assessed and evaluated, particularly if new processing takes place or if processing is deemed to present a risk to the rights and freedoms of individuals;
  11. performance with handling personal information is regularly assessed and evaluated;
  12. breaches of personal data are promptly assessed, contained and mitigated;
  13. breaches of personal data are reported to the ICO and data subjects where necessary; and
  14. a breach of the rules and procedures identified in this policy by a member of staff may lead to disciplinary action being taken.

IT security

Fishawack-hosted online tools/websites are password-protected for limited access only by identified individuals (e.g. client team members) via secure internet connection (SSL encryption and security log in to ensure high security levels). Server hosting infrastructure and terms & conditions can be provided upon request.

Right to access personal information

Under the UK Data Protection Act 1998 and other European Data Protection laws data subjects have a right to request a copy of the personal data we hold about them, or to request that it be updated, corrected or removed (in which case we will address your request promptly and will notify our clients of all such requests or changes). We will update your information as requested by you.

Status of this policy

Responsibility for the updating and dissemination of the policy rests with Fishawack’s Data Protection Officer. Any questions or concerns about the operation of this policy should be referred in the first instance to the Data Protection Officer at the details below.


The Data Protection Officer
Fishawack Communications
100-102 King Street
Knutsford, WA16 6HQ, UK
Tel: +44 (0)1565 756600
Fax: +44 (0)1565 750611

This policy is subject to regular review and will be updated as necessary to reflect any changes in Fishawack’s operational activities, best practice in data management, security and control and to ensure compliance with any changes or amendments made to applicable law.

In the event that an individual is not satisfied with the way in which we are processing their personal data, they have the right to make a complaint with the Information Commissioner’s Office.

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Fishawack Ltd
Company registration no: 06445583  Registered office: Knutsford
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