1. Definition

All processing of personal data by Jiffy Packaging Company Limited is within the scope of this procedure.

2. Responsibilities

2.1 The Data Protection Officer / GDPR Representative is responsible for ensuring that the privacy notice(s) is correct and that mechanisms exist such as having the following:

• Privacy Notice(s) on Jiffy Packaging Company Limited website to make all data subjects aware of the contents of this notice prior to Jiffy Packaging Company Limited commencing collection of their data.

• All staff that need to collect personal data are required to follow this
procedure.

3. Procedure Article 12

3.1.1 Jiffy Packaging Company Limited identifies the legal basis for processing personal data before any processing operations take place by clearly establishing, defining and documenting the specific purpose of processing the personal data and the legal basis to process the data under:

• consent obtained from the data subject

• performance of a contract where the data subject is a party

• legal obligation that our company is required to meet

• protect the vital interests of the data subject, including the protection of rights and freedoms

• official authority of Jiffy Packaging Company Limited or to carry out the
processing that is in the public interest

• necessary for the legitimate interests of the data controller or third party, unless the processing is overridden by the vital interests, including rights and freedoms

• national law

3.1.2 Any special categories of personal data processed and the legal basis to process the data under:

• explicit consent obtained from the data subject

• necessary for employment rights or obligations

• protect the vital interests of the data subject, including the
protection of rights and freedoms

• necessary for the legitimate activities with appropriate
safeguards

• personal data made public by the data subject

• legal claims

• substantial public interest

• preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, provision of health or social care treatment, or management of health and social care systems and services, under the basis that
appropriate contracts with health professionals and safeguards are in place

• public health, ensuring appropriate safeguards are in place for the
protection of rights and freedoms of the data subject, or
professional secrecy

• national laws in terms of processing genetic, biometric or health data

3.2 Jiffy Packaging Company Limited records this information in line with its data protection impact assessment and data inventory.

4. Privacy Notices

4.1 When personal data is collected from data subject with consent, Jiffy Packaging Company Limited is transparent in its processing of personal data and
provides the data subject with the following:

• Jiffy Packaging Company Limited identity, and contact details of the Data Protection Officer / GDPR Representative and any data protection
representatives

• The purpose(s), including legal basis, for the intended processing of
personal data (clause 4.2 below);

• Where relevant, Jiffy Packaging Company Limited legitimate interests that provide the legal basis for the processing

• Potential recipients of personal data

• Any information regarding the intention to disclose personal data to third parties and whether it is transferred outside the EU. In such circumstances, Jiffy Packaging Company Limited will provide information on the safeguards in place and how the data subject can also obtain a copy of these safeguards

• If Jiffy Packaging Company Limited is based outside of the EU and the data subject resides within it (the EU), the Jiffy Packaging Company
Limited provides the data subject with contact details of a data
protection representative in the EU

• Any information on website technologies used to collect personal data about the data subject

• Any other information required to demonstrate that the processing is fair and transparent.

4.2 All information provided to the data subject is in an easily accessible format,
examples being printed letter, email, PDF form, using clear and plain language, especially for personal data addressed to a child

• Jiffy Packaging Company Limited facilitates the data subject’s rights in line with the data protection policy and the subject access request procedure

• Privacy notice for this personal data processing is recorded

4.3 When data is contractually required for processing

• Jiffy Packaging Company Limited processes data without consent in
order to fulfil contractual obligations such as bank details to process salaries, postal address in order to supply products and services, etc.

• Privacy notice for this personal data processing is recorded

4.4 When personal data has been obtained from a source other than the data
subject Jiffy Packaging Company Limited makes clear the types of information collected as well as the source of the personal data (publicly
accessible sources) and provides the data subject with:

• Jiffy Packaging Company Limited (data controller) identity, and contact details of the Data Protection Officer / GDPR Representative and any data protection representatives

• The purpose(s), including legal basis, for the intended processing of personal data

• Categories of personal data

• Potential recipients of personal data

• Any information regarding disclosing personal data to third parties and whether it is transferred outside the EU – Jiffy Packaging Company Limited will provide information on the safeguards in place and how the data subject can also obtain a copy of these safeguards

• Any other information required to demonstrate that the processing is fair and transparent

• Privacy notice for this personal data processing is recorded

5. Jiffy Packaging Company Limited provides the information stated in clauses 3 and 4 above within:

• one month of obtaining the personal data, in accordance with the
specific circumstances of the processing

• at the first instance of communicating in circumstances where the
personal data is used to communicate with the data subject

• when personal data is first disclosed in circumstances where the
personal data is disclosed to another recipient.

5.1. Clauses 3 and 4 above do not apply:

• If the data subject already has the information

• If the provision of the above information proves impossible or would
involve an excessive effort

• If obtaining or disclosure of personal data is expressly identified by Member State law

• If personal data must remain confidential subject to an obligation of professional secrecy regulated by Member State law, including a
statutory obligation of secrecy