Data Protection Policy

AngelScope International Data Protection Policy

 

DATA PROTECTION POLICY

AngelScope International Ltd

1. Policy Statement

AngelScope International Ltd (“AngelScope”) is committed to protecting the rights and freedoms of individuals by ensuring that personal data is processed lawfully, fairly, transparently and securely.

This Policy establishes the framework through which AngelScope complies with the requirements of the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable data protection legislation.

All employees, contractors, consultants and third parties acting on behalf of AngelScope are required to comply with this Policy.

2. Purpose

The purpose of this Policy is to ensure that:

  • Personal data is processed lawfully, fairly and transparently.
  • Personal data is collected for specified, explicit and legitimate purposes.
  • Personal data is accurate, relevant and limited to what is necessary.
  • Appropriate security measures are implemented to safeguard personal data.
  • Individuals’ rights are protected.
  • AngelScope meets its legal and regulatory obligations.

3. Scope

This Policy applies to:

  • All employees;
  • Directors;
  • Contractors;
  • Agency workers;
  • Consultants;
  • Volunteers;
  • Third-party service providers processing personal data on behalf of AngelScope.

The Policy applies to all personal data processed by AngelScope, whether held electronically, on paper, in email systems, cloud platforms, mobile devices or other storage media.

4. Data Controller

AngelScope International Ltd is the Data Controller responsible for determining the purposes and means of processing personal data.

ICO Registration Number: ZB583820

Registered Office:
27 Wilcox Close
London
SW8 2UD
United Kingdom

Email: info@angelscope.co.uk 

5. Data Protection Principles

AngelScope will ensure that personal data is:

Lawful, Fair and Transparent

Processed only where a lawful basis exists and individuals are provided with appropriate privacy information.

Purpose Limitation

Collected only for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes.

Data Minimisation

Limited to the information necessary to fulfil the intended purpose.

Accuracy

Kept accurate and up to date where reasonably practicable.

Storage Limitation

Retained only for as long as necessary.

Integrity and Confidentiality

Protected by appropriate technical and organisational security measures.

Accountability

Processed in a manner that demonstrates compliance with applicable data protection legislation.

6. Roles and Responsibilities

Management is responsible for ensuring that appropriate measures are implemented to achieve compliance with applicable data protection legislation.

All employees, contractors, consultants and persons acting on behalf of AngelScope must:

  • Comply with this Policy and all related procedures;
  • Process personal data only where authorised and necessary;
  • Protect the confidentiality, integrity and availability of personal data;
  • Report actual or suspected personal data breaches immediately;
  • Complete any data protection training required by the organisation;
  • Follow all security and confidentiality requirements relating to personal data.

Failure to comply with this Policy may result in disciplinary action and, where appropriate, legal action.

7. Categories of Personal Data

AngelScope may process:

  • Names and contact details;
  • Addresses;
  • Dates of birth;
  • Identification documents;
  • Payment and billing information;
  • Employment-related information;
  • Customer and client records;
  • Website and communication records;
  • Health information;
  • Drug and alcohol testing information;
  • DNA and genetic testing information;
  • Special Category Personal Data where required for legitimate business purposes.

8. Lawful Basis for Processing

AngelScope shall only process personal data where a lawful basis exists under Article 6 of the UK General Data Protection Regulation (UK GDPR).

Where Special Category Personal Data is processed, including health information, genetic data, DNA testing information, drug and alcohol testing information, an additional condition under Article 9 UK GDPR shall also apply.

AngelScope shall ensure that the lawful basis and any applicable Article 9 condition are identified, documented and reviewed where required.

9. Special Category Data

AngelScope recognises that health information, genetic data, and drug and alcohol testing information constitute Special Category Personal Data under Article 9 UK GDPR.

Such information shall only be processed where:

  • A lawful basis under Article 6 UK GDPR applies; and
  • An additional condition under Article 9 UK GDPR is satisfied.

Access to Special Category Personal Data shall be restricted to authorised personnel with a legitimate business need.

10. Data Security

AngelScope shall implement appropriate technical and organisational measures to protect personal data from:

  • Unauthorised access;
  • Unauthorised disclosure;
  • Accidental loss;
  • Destruction;
  • Damage;
  • Alteration;
  • Misuse.

Security measures may include:

  • Access controls;
  • Password protection;
  • Multi-factor authentication;
  • Secure storage systems;
  • Encrypted data transmission where appropriate;
  • Secure disposal procedures;
  • Confidentiality agreements;
  • Staff training and awareness.

11. Access to Personal Data

Access to personal data will be granted only to individuals whose duties require such access.

Personnel must:

  • Maintain confidentiality;
  • Use personal data only for authorised purposes;
  • Report any security incidents immediately;
  • Comply with this Policy and related procedures.

12. Data Retention

Personal data shall be retained only for as long as necessary to fulfil the purpose for which it was collected and to meet legal, regulatory and business requirements.

When retention periods expire, personal data shall be securely deleted, anonymised or destroyed.

13. Data Sharing

AngelScope may share personal data with:

  • Accredited laboratories;
  • Healthcare professionals;
  • Legal representatives;
  • Accountants and professional advisers;
  • Information technology service providers;
  • Payment service providers;
  • Regulators and public authorities where legally required.

All third-party processors must provide appropriate safeguards and comply with applicable data protection legislation.

14. International Transfers

Where personal data is transferred outside the United Kingdom, AngelScope shall ensure that suitable safeguards are implemented in accordance with UK GDPR requirements.

15. Individual Rights

AngelScope recognises and supports the rights of individuals under UK GDPR, including:

  • The right to be informed;
  • The right of access;
  • The right to rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to data portability;
  • The right to object;
  • Rights relating to automated decision-making and profiling.

Requests concerning these rights shall be handled without undue delay and within the timeframes required by law.

16. Subject Access Requests

Any individual who wishes to access their personal data may submit a Subject Access Request.

Requests should be directed to:

Email: info@angelscope.co.uk

AngelScope will respond in accordance with UK GDPR requirements and applicable legislation.

17. Personal Data Breaches

Any actual or suspected personal data breach must be reported immediately to management.

AngelScope will:

  • Investigate the incident;
  • Contain risks where possible;
  • Assess the impact;
  • Notify the Information Commissioner’s Office (ICO) where required;
  • Notify affected individuals where required by law;
  • Maintain records of breaches and corrective actions.

18. Training and Awareness

All personnel handling personal data must receive appropriate guidance and awareness regarding their data protection responsibilities.

Training and awareness measures shall be reviewed periodically to ensure compliance with current legislation and recognised best practice.

19. Monitoring and Compliance

AngelScope will periodically review its data protection practices, procedures and safeguards to ensure ongoing compliance with applicable legislation and regulatory expectations.

Failure to comply with this Policy may result in disciplinary action and, where appropriate, legal action.

20. Policy Review

This Policy shall be reviewed at least annually and updated where necessary to reflect changes in legislation, regulatory guidance, business operations, services or risks associated with the processing of personal data.

21. Document Control

Policy Owner: AngelScope International Ltd

Approved By: Director

Version: 1.0

Effective Date: 21 October 2026

Review Date: October 2027

This Policy shall be reviewed at least annually, or sooner if required due to changes in legislation, regulatory requirements, business operations or guidance issued by the Information Commissioner’s Office (ICO).

AngelScope International Ltd
ICO Registration Number: ZB583820
Version 1.0
Effective Date: 21 October 2026
Review Date: October 2027

 

 

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