Barton Manor Hotel and Spa

PRIVACY STANDARD

1. INTERPRETATION

1.1 DEFINITIONS:

Automated Decision-Making (ADM): when a decision is made
which is based solely on Automated

Processing (including profiling) which produces legal
effects or significantly affects an individual. The

GDPR prohibits Automated Decision-Making (unless certain
conditions are met) but not Automated

Processing.

Automated Processing: any form of automated processing of
Personal Data consisting of the use of

Personal Data to evaluate certain personal aspects relating
to an individual, in particular to analyse

or predict aspects concerning that individual’s performance
at work, economic situation, health,

personal preferences, interests, reliability, behaviour,
location or movements. Profiling is an example

of Automated Processing.

Company name: Barton Manor Hotel & Spa Ltd

Company Personnel: all employees, workers, contractors,
agency workers, consultants, directors,

members and others.

Consent: agreement which must be freely given, specific, informed
and be an unambiguous

indication of the Data Subject’s wishes by which they, by a
statement or by a clear positive action,

signifies agreement to the Processing of Personal Date
relating to them.

Explicit Consent: consent which requires a very clear and
specific statement (that is, not just action).

General Data Protection Regulation (GDPR): the General Data
Protection Regulation ((EU)

2016/679). Personal Data is subject to the legal safeguards
specified in the GDPR.

Personal Data: any information identifying a Data Subject or
information relating to a Data Subject

that we can identify (directly or indirectly) from that data
alone or in combination with other

identifiers we possess or can reasonably access. Personal
Data includes Sensitive Personal Data and

Pseudonymised Personal Data but excludes anonymous data or
data that has had the identity of an

individual permanently removed. Personal data can be factual
(for example, a name, email address,

location or date of birth) or an opinion about that person’s
actions or behaviour.

Personal Data Breach: any act or omission that compromises
the security, confidentiality, integrity

or availability of Personal Data or the physical, technical,
administrative or organisational safeguards

that we or our third-party service providers put in place to
protect it. The loss, or unauthorised

access, disclosure or acquisition, of Personal Data is a
Personal Data Breach.

Privacy by Design: implementing appropriate technical and
organisational measures in an effective

manner to ensure compliance with the GDPR.

Privacy Guidelines: the Company privacy/GDPR related
guidelines provided to assist in interpreting

and implementing this Privacy Standard.

Privacy Notices (also referred to as Fair Processing
Notices) or Privacy Policies: separate notices

setting out information that may be provided to Data
Subjects when the Company collects

information about them. These notices may take the form of
general privacy statements applicable

to a specific group of individuals (for example, employee
privacy notices or the website privacy

policy) or they may be stand-alone, one time privacy
statements covering Processing related to a

specific purpose.

Processing or Process: any activity that involves the use of
Personal Data. It includes 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 transmitting or transferring Personal Data to third
parties.

Pseudonymisation or Pseudonymised: replacing information
that directly or indirectly identifies an

individual with one or more artificial identifiers or
pseudonyms so that the person, to whom the

data relates, cannot be identified without the use of
additional information which is meant to be

kept separately and secure.

Related Policies: the Company’s policies, operating
procedures or processes related to this Privacy

Standard and designed to protect Personal Data.

Sensitive Personal Data: information revealing racial or
ethnic origin, political opinions, religious or

similar beliefs, trade union membership, physical or mental
health conditions, sexual life, sexual

orientation, biometric or genetic data, and Personal Data
relating to criminal offences and

convictions.

2. INTRODUCTION

This Privacy Standard sets out how Barton Manor Hotel &
Spa Ltd (”we”, “our”, “us”, “the Company”)

handle the Personal Data of our customers, suppliers,
employees, workers and other third parties.

This Privacy Standard applies to all Personal Data we
Process regardless of the media on which that

data is stored or whether it relates to past or present
employees, workers, customers, clients or

supplier contacts, shareholders, website users or any other
Data Subject. This Privacy Standard

applies to all Company Personnel (”you”, “your”). You must
read, understand and comply with this

Privacy Standard when Processing Personal Data on our behalf
and attend training on its

requirements. This Privacy Standard sets out what we expect
from you in order for the Company to

comply with applicable law. Your compliance with this
Privacy Standard is mandatory. Related

Policies and Privacy Guidelines are available to help you
interpret and act in accordance with this

Privacy Standard. You must also comply with all such Related
Policies and Privacy Guidelines. Any

breach of this Privacy Standard may result in disciplinary
action.

This Privacy Standard (together with Related Policies and
Privacy Guidelines) is an internal document

and cannot be shared with third parties, clients or
regulators without prior authorisation from the

DPO.

3. SCOPE

We recognise that the correct and lawful treatment of
Personal Data will maintain confidence in the

organisation and will provide for successful business
operations. Protecting the confidentiality and

integrity of Personal Data is a critical responsibility that
we take seriously at all times. The Company

is exposed to potential fines of up to EUR20 million
(approximately £18 million) or 4% of total

worldwide annual turnover, whichever is higher and depending
on the breach, for failure to comply

with the provisions of the GDPR.

All departments are responsible for ensuring all Company
Personnel comply with this Privacy

Standard and need to implement appropriate practices,
processes, controls and training to ensure

such compliance.

The DPO is responsible for overseeing this Privacy Standard
and, as applicable, developing Related

Policies and Privacy Guidelines. That post is held by Leigh
Walker.

Please contact the DPO with any questions about the
operation of this Privacy Standard or the GDPR

or if you have any concerns that this Privacy Standard is
not being or has not been followed. In

particular, you must always contact the DPO in the following
circumstances:

(a) if you are unsure of the lawful basis which you are
relying on to process Personal Data (including

the legitimate interests used by the Company) (see Section
5.1 below);

(b) if you need to rely on Consent and/or need to capture
Explicit Consent (see Section 5.2 below);

(d) if you are unsure about the retention period for the
Personal Data being Processed (see Section 9

below);

(e) if you are unsure about what security or other measures
you need to implement to protect

Personal Data (see Section 10.1 below);

(f) if there has been a Personal Data Breach (Section 10.2
below);

(g) if you are unsure on what basis to transfer Personal
Data outside the EEA (see Section 11 below);

(h) if you need any assistance dealing with any rights
invoked by a Data Subject (see Section 12);

(i) whenever you are engaging in a significant new, or
change in, Processing activity which is likely to

require a DPIA (see Section 13.4 below) or plan to use
Personal Data for purposes others than what

it was collected for;

(j) if you plan to undertake any activities involving
Automated Processing including profiling or

Automated Decision-Making (see Section 13.5 below).

(k) if you need help complying with applicable law when
carrying out direct marketing activities (see

Section 13.6 below).

(l) if you need help with any contracts or other areas in
relation to sharing Personal Data with this

parties (including our vendors) (See Section 13.7 below).

4. PERSONAL DATA PROTECTION PRINCIPLES

We adhere to the principles relating to Processing of
Personal Data set out in the GDPR which

require Personal Data to be:

(a) Processed lawfully, fairly and in a transparent manner
(Lawfulness, Fairness and Transparency).

(b) Collected only for specified, explicit and legitimate
purposes (Purpose Limitation).

Processed (Data Minimisation).

(d) Accurate and where necessary kept up to date (Accuracy).

(e) Not kept in a form which permits identification of Data
Subjects for longer than is necessary for

the purposes for which the data is Processed (Storage
Limitation).

(f) Processed in a manner that ensures its security using
appropriate technical and organisational

measures to protect against unauthorised or unlawful
Processing and against accidental loss,

destruction or damage (Security, Integrity and
Confidentiality).

(g) Not transferred to another country without appropriate
safeguards being in place (Transfer

Limitation).

(h) Made available to Data Subjects and Data Subjects
allowed to exercise certain rights in relation to

their Personal Data (Data Subject’s Rights and Requests).

We are responsible for and must be able to demonstrate
compliance with the data protection

principles listed above (Accountability).

5. LAWFULNESS, FAIRNESS, TRANSPARENCY

5.1 LAWFULNESS AND FAIRNESS

Personal data must be Processed lawfully, fairly and in a
transparent manner in relation to the Data

Subject.

You may only collect, Process and share Personal Data fairly
and lawfully and for specified purposes.

The GDPR restricts our actions regarding Personal Data to
specified lawful purposes. These

restrictions are not intended to prevent Processing, but
ensure that we Process Personal Data fairly

and without adversely affecting the Data Subject.

The GDPR allows Processing for specific purposes, some of
which are set out below:

(a) the Data Subject has given his or her Consent;

(b) the Processing is necessary for the performance of a
contract with the Data Subject;

(d) to protect the Data Subject’s vital interests;

(e) to pursue our legitimate interests for purposes where
they are not overridden because the

Processing prejudices the interests or fundamental rights
and freedoms of Data Subjects. The

purposes for which we process Personal Data for legitimate
interests need to be set out in applicable

Privacy Notices or Fair Processing Notices;

You must identify and document the legal ground being relied
on for each Processing activity.

5.2 CONSENT

A Data Controller must only process Personal Data on the
basis of one or more of the lawful bases

set out in the GDPR, which include Consent.

A Data Subject consents to Processing of their Personal Data
if they indicate agreement clearly either

by a statement or positive action to the Processing. Consent
requires affirmative action so silence,

pre-ticked boxes or inactivity are unlikely to be
sufficient. If Consent is given in a document which

deals with other matters, then the Consent must be kept
separate from those other matters.

Data Subjects must be easily able to withdraw Consent to
Processing at any time and withdrawal

must be promptly honoured. Consent may need to be refreshed
if you intend to Process Personal

Data for a different and incompatible purpose which was not
disclosed when the Data Subject first

consented.

Unless we can rely on another legal basis of Processing,
Explicit Consent is usually required for

Processing Sensitive Personal Data, for Automated
Decision-Making and for cross border data

transfers. Usually we will be relying on another legal basis
(and not require Explicit Consent) to

Process most types of Sensitive Data. Where Explicit Consent
is required, you must issue a Fair

Processing Notice to the Data Subject to capture Explicit Consent.

You will need to evidence Consent captured and keep records
of all Consents so that the Company

can demonstrate compliance with Consent requirements.

5.3 TRANSPARENCY (NOTIFYING DATA SUBJECTS)

The GDPR requires Data Controllers to provide detailed,
specific information to Data Subjects

depending on whether the information was collected directly
from Data Subjects or from elsewhere.

Such information must be provided through appropriate
Privacy Notices or Fair Processing Notices

which must be concise, transparent, intelligible, easily
accessible, and in clear and plain language so

that a Data Subject can easily understand them.

Whenever we collect Personal Data directly from Data
Subjects, including for human resources or

employment purposes, we must provide the Data Subject with
all the information required by the

GDPR including the identity of the Data Controller and DPO,
how and why we will use, Process,

disclose, protect and retain that Personal Data through a
Fair Processing Notice which must be

presented when the Data Subject first provides the Personal
Data.

When Personal Data is collected indirectly (for example,
from a third party or publically available

source), you must provide the Data Subject with all the
information required by the GDPR as soon as

possible after collecting/receiving the data. You must also
check that the Personal Data was

collected by the third party in accordance with the GDPR and
on a basis which contemplates our

proposed Processing of that Personal Data.

6. PURPOSE LIMITATION

Personal Data must be collected only for specified, explicit
and legitimate purposes. It must not be

further Processed in any manner incompatible with those
purposes.

You cannot use Personal Data for new, different or
incompatible purposes from that disclosed when

it was first obtained unless you have informed the Data
Subject of the new purposes and they have

Consented where necessary.

7. DATA MINIMISATION

Personal Data must be adequate, relevant and limited to what
is necessary in relation to the

purposes for which it is Processed.

You may only Process Personal Data when performing your job
duties requires it. You cannot

Process Personal Data for any reason unrelated to your job
duties.

You may only collect Personal Data that you require for your
job duties: do not collect excessive

data. Ensure any Personal Data collected is adequate and
relevant for the intended purposes.

You must ensure that when Personal Data is no longer needed
for specified purposes, it is deleted or

anonymised in accordance with the Company’s data retention
guidelines.

8. ACCURACY

Personal Data must be accurate and, where necessary, kept up
to date. It must be corrected or

deleted without delay when inaccurate.

You will ensure that the Personal Data we use and hold is
accurate, complete, kept up to date and

relevant to the purpose for which we collected it. You must
check the accuracy of any Personal Data

at the point of collection and at regular intervals
afterwards. You must take all reasonable steps to

destroy or amend inaccurate or out-of-date Personal Data.

9. STORAGE LIMITATION

Personal Data must not be kept in an identifiable form for
longer than is necessary for the purposes

for which the data is processed.

You must not keep Personal Data in a form which permits the identification
of the Data Subject for

longer than needed for the legitimate business purpose or
purposes for which we originally collected

it including for the purpose of satisfying any legal,
accounting or reporting requirements.

The Company will maintain retention policies and procedures
to ensure Personal Data is deleted

after a reasonable time for the purposes for which it was
being held, unless a law requires such data

to be kept for a minimum time. [You must comply with the
Company’s guidelines on Data

Retention.]

You will take all reasonable steps to destroy or erase from
our systems all Personal Data that we no

longer require in accordance with all the Company’s
applicable records retention schedules and

policies. This includes requiring third parties to delete
such data where applicable.

You will ensure Data Subjects are informed of the period for
which data is stored and how that

period is determined in any applicable Privacy Notice or
Fair Processing Notice.

10. SECURITY INTEGRITY AND CONFIDENTIALITY

10.1 PROTECTING PERSONAL DATA

Personal Data must be secured by appropriate technical and
organisational measures against

unauthorised or unlawful Processing, and against accidental
loss, destruction or damage.

We will develop, implement and maintain safeguards
appropriate to our size, scope and business,

our available resources, the amount of Personal Data that we
own or maintain on behalf of others

and identified risks (including use of encryption and
Pseudonymisation where applicable). We will

regularly evaluate and test the effectiveness of those
safeguards to ensure security of our Processing

of Personal Data. You are responsible for protecting the
Personal Data we hold. You must implement

reasonable and appropriate security measures against unlawful
or unauthorised Processing of

Personal Data and against the accidental loss of, or damage
to, Personal Data. You must exercise

particular care in protecting Sensitive Personal Data from
loss and unauthorised access, use or

disclosure.

You must follow all procedures and technologies we put in
place to maintain the security of all

Personal Data from the point of collection to the point of
destruction. You may only transfer

Personal Data to third-party service providers who agree to
comply with the required policies and

procedures and who agree to put adequate measures in place,
as requested.

You must maintain data security by protecting the
confidentiality, integrity and availability of the

Personal Data, defined as follows:

(a) Confidentiality means that only people who have a need
to know and are authorised to use the

Personal Data can access it.

(b) Integrity means that Personal Data is accurate and
suitable for the purpose for which it is

processed.

for authorised purposes.

You must comply with and not attempt to circumvent the
administrative, physical and technical

safeguards we implement and maintain in accordance with the
GDPR and relevant standards to

protect Personal Data.

10.2 REPORTING A PERSONAL DATA BREACH

The GDPR requires Data Controllers to notify any Personal
Data Breach to the applicable regulator

and, in certain instances, the Data Subject.

We have put in place procedures to deal with any suspected
Personal Data Breach and will notify

Data Subjects or any applicable regulator where we are
legally required to do so.

If you know or suspect that a Personal Data Breach has
occurred, do not attempt to investigate the

matter yourself. Immediately contact the person or team
designated as the key point of contact for

Personal Data Breaches. You should preserve all evidence
relating to the potential Personal Data

Breach.

11. TRANSFER LIMITATION

The GDPR restricts data transfers to countries outside the
EEA in order to ensure that the level of

data protection afforded to individuals by the GDPR is not
undermined. You transfer Personal Data

originating in one country across borders when you transmit,
send, view or access that data in or to

a different country.

You may only transfer Personal Data outside the EEA if one
of the following conditions applies:

(a) the European Commission has issued a decision confirming
that the country to which we transfer

the Personal Data ensures an adequate level of protection
for the Data Subjects’ rights and

freedoms;

(b) appropriate safeguards are in place such as binding
corporate rules (BCR), standard contractual

clauses approved by the European Commission, an approved
code of conduct or a certification

mechanism, a copy of which can be obtained from the DPO;

any potential risks; or

(d) the transfer is necessary for one of the other reasons
set out in the GDPR including the

performance of a contract between us and the Data Subject,
reasons of public interest, to establish,

exercise or defend legal claims or to protect the vital
interests of the Data Subject where the Data

Subject is physically or legally incapable of giving Consent
and, in some limited cases, for our

legitimate interest.

12. DATA SUBJECT’S RIGHTS AND REQUESTS

Data Subjects have rights when it comes to how we handle
their Personal Data. These include rights

to:

(a) withdraw Consent to Processing at any time;

(b) receive certain information about the Data Controller’s
Processing activities;

(d) prevent our use of their Personal Data for direct
marketing purposes;

(e) ask us to erase Personal Data if it is no longer
necessary in relation to the purposes for which it

was collected or Processed or to rectify inaccurate data or
to complete incomplete data;

(f) restrict Processing in specific circumstances;

(g) challenge Processing which has been justified on the
basis of our legitimate interests or in the

public interest;

(h) request a copy of an agreement under which Personal Data
is transferred outside of the EEA;

(i) object to decisions based solely on Automated
Processing, including profiling (ADM);

(j) prevent Processing that is likely to cause damage or
distress to the Data Subject or anyone else;

(k) be notified of a Personal Data Breach which is likely to
result in high risk to their rights and

freedoms;

(l) make a complaint to the supervisory authority; and

(m) in limited circumstances, receive or ask for their
Personal Data to be transferred to a third party

in a structured, commonly used and machine readable format.

You must verify the identity of an individual requesting
data under any of the rights listed above (do

not allow third parties to persuade you into disclosing
Personal Data without proper authroisation).

You must immediately forward any Data Subject request you
receive through the DPO.

13. ACCOUNTABILITY

13.1 The Data Controller must implement appropriate
technical and organisational measures in an

effective manner, to ensure compliance with data protection
principals. The Data Controller is

responsible for, and must be able to demonstrate, compliance
with the data protection principles.

The company must have adequate resources and controls in
place to ensure and to

document GDPR compliance including:

(a) appointing a suitably qualified DPO (where necessary)
and an executive accountable

for data privacy;

(b) implementing Privacy by Design when Processing Personal
Data and completing

DPIAs where Processing presents a high risk to rights and
freedoms of Data Subjects;

Related Policies, Privacy Guidelines, Privacy Notices and
Fair Processing Notices;

(d) regularly training Company Personnel on the GDPR, this
Privacy Statement Related

Policies, Privacy Guidelines and data protection matters
including, for example, Data

Subject’s rights, Consent, legal basis, DPIA and Personal
Data Breaches. The

Company must maintain a record of training attendance by
Company Personnel; and

(e) regularly testing the privacy measures implemented and
conducting periodic

reviews and audits to assess compliance, including using
results of testing to

demonstrate compliance improvement effort.

13.2 RECORD KEEPING

The GDPR requires us to keep full and accurate records of
all our data Processing activities.

You must keep and maintain accurate corporate records
reflecting our Processing including records

of Data Subjects’ Consents and procedures for obtaining
Consents in accordance with the Company’s

record keeping guidelines.

These records should include, at a minimum, the name and
contact details of the Data Controller

and the DPO, clear descriptions of the Personal Data types,
Data Subject types, Processing activities,

Processing purposes, third-party recipients of the Personal
Data, Personal Data storage locations,

Personal Data transfers, the Personal Data’s retention
period and a description of the security

measures in place. In order to create such records, data
maps should be created which should

include the detail set out above together with appropriate
data flows.

13.3 TRAINING AND AUDIT

We are required to ensure all Company Personnel have
undergone adequate training to enable

them to comply with data privacy laws. We must also
regularly test our systems and processes to

assess compliance.

You must undergo all mandatory data privacy related training
and ensure your team undergo similar

mandatory training.

You must regularly review all the systems and processes
under your control to ensure they comply

with this Privacy Standard and check that adequate
governance controls and resources are in place

to ensure proper use and protection of Personal Data.

13.4 PRIVACY BY DESIGN AND DATA PROTECTION IMPACT ASSESSMENT
(DPIA)

We are required to implement Privacy by Design measures when
Processing Personal Data by

implementing appropriate technical and organisational
measures (like Pseudonymisation) in an

effective manner, to ensure compliance with data privacy
principles.

You must assess what Privacy by Design measures can be
implemented on all

programs/systems/processes that Process Personal Data by
taking into account the following:

(a) the state of the art;

(b) the cost of implementation;

(d) the risks of varying likelihood and severity for rights
and freedoms of Data Subjects posed by the

Processing.

Data controllers must also conduct DPIAs in respect to high
risk Processing.

You should conduct a DPIA (and discuss your findings with
the DPO) when implementing major

system or business change programs involving the Processing
of Personal Data including:

(e) use of new technologies (programs, systems or
processes), or changing technologies (programs,

systems or processes);

(f) Automated Processing including profiling and ADM;

(g) large scale Processing of Sensitive Data; and

(h) large scale, systematic monitoring of a publicly
accessible area.

A DPIA must include:

(i) a description of the Processing, its purposes and the
Data Controller’s legitimate interests if

appropriate;

(j) an assessment of the necessity and proportionality of
the Processing in relation to its purpose;

(k) an assessment of the risk to individuals; and

(l) the risk mitigation measures in place and demonstration
of compliance.

13.5 AUTOMATED PROCESSING (INCLUDING PROFILING) AND
AUTOMATED DECISION-MAKING

Generally, ADM is prohibited when a decision has a legal or
similar significant effect on an individual

unless:

(a) a Data Subject has Explicitly Consented;

(b) the Processing is authorised by law; or

If certain types of Sensitive Data are being processed, then
grounds (b) or (c) will not be allowed but

such Sensitive Data can be Processed where it is necessary
(unless less intrusive means can be used)

for substantial public interest like fraud prevention.

If a decision is to be based solely on Automated Processing
(including profiling), then Data Subjects

must be informed when you first communicate with them of
their right to object. This right must be

explicitly brought to their attention and presented clearly
and separately from other information.

Further, suitable measures must be put in place to safeguard
the Data Subject’s rights and freedoms

and legitimate interests.

We must also inform the Data Subject of the logic involved
in the decision making or profiling, the

significance and envisaged consequences and give the Data
Subject the right to request human

intervention, express their point of view or challenge the
decision.

A DPIA must be carried out before any Automated Processing
(including profiling) or ADM activities

are undertaken.

Where you are involved in any data Processing activity that
involves profiling or ADM, you must

comply with the Company’s guidelines on profiling or ADM.

13.6 DIRECT MARKETING

We are subject to certain rules and privacy laws when
marketing to our customers.

For example, a Data Subject’s prior consent is required for
electronic direct marketing (for example,

by email, text or automated calls). The limited exception
for existing customers known as “soft opt

in” allows organisations to send marketing texts or emails
if they have obtained contact details in

the course of a sale to that person, they are marketing
similar products or services, and they gave

the person an opportunity to opt out of marketing when first
collecting the details and in every

subsequent message.

The right to object to direct marketing must be explicitly
offered to the Data Subject in an intelligible

manner so that it is clearly distinguishable from other
information.

A Data Subject’s objection to direct marketing must be
promptly honoured. If a customer opts out at

any time, their details should be suppressed as soon as
possible. Suppression involves retaining just

enough information to ensure that marketing preferences are
respected in the future.

You must comply with the Company’s guidelines on direct
marketing to customers.

13.7 SHARING PERSONAL DATA

Generally we are not allowed to share Personal Data with
third parties unless certain safeguards and

contractual arrangements have been put in place.

You may only share the Personal Data we hold with another
employee, agent or representative of

our group (which includes our subsidiaries and our ultimate
holding company along with its

subsidiaries) if the recipient has a job-related need to
know the information and the transfer

complies with any applicable cross-border transfer
restrictions.

You may only share the Personal Data we hold with third
parties, such as our service providers if:

(a) they have a need to know the information for the
purposes of providing the contracted services;

(b) sharing the Personal Data complies with the Privacy
Notice provided to the Data Subject and, if

required, the Data Subject’s Consent has been obtained;

procedures and put adequate security measures in place;

(d) the transfer complies with any applicable cross border
transfer restrictions; and

(e) a fully executed written contract that contains GDPR
approved third party clauses has been

obtained.

You must comply with the Company’s guidelines on sharing
data with third parties.

14. CHANGES TO THIS PRIVACY STANDARD

We reserve the right to change this Privacy Standard at any
time without notice to you so please

check back regularly to obtain the latest copy of this
Privacy Standard. This Privacy Standard does

not override any applicable national data privacy laws and
regulations in countries where the

Company operates.

Privacy Policy