Data Protection Policy


In the course of its business NDF Associates Ltd processes personal data. The company regards the lawful and correct treatment of personal information as being of paramount importance and therefore ensures that personal information is treated lawfully and correctly. To this end the Company fully endorses and adheres to the Principles of Data Protection, as detailed in the Data Protection Act 1998 and associated legislation and Codes of Practice.



Specifically, the Principles require that personal information


1. shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met,


2. shall be obtained only for one or more specified and lawful 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 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.



Furthermore there is a requirement that appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data


The Company will, through appropriate management, strict application of criteria and controls


1. observe fully conditions regarding the fair collection and use of information,


2. meet its legal obligations to specify the purposes for which information is used,


3. collect and process appropriate information, and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements,


4. ensure the quality of information used,


5. apply strict checks to determine the length of time information is held,


6. ensure that the rights of individuals  about whom information is held, can be fully exercised under the Act. (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 inaccurate information),


7. take appropriate technical and organisational security measures to safeguard personal information,


8. ensure that personal information is not transferred abroad without suitable safeguards,


9. treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information,


10. set out clear procedures for responding to requests for information.



In addition, the company will ensure that:


1. there is an identifiable individual  with specific responsibility for Data Protection. The Company’s  Data Protection Officer is the Operations Director


2. all staff and others contracted to the company and responsible for managing and handling personal information understand that they are contractually responsible for following good data protection practice,


3. all individuals managing and handling personal information are appropriately trained to do so,


4. all individuals managing and handling personal information are appropriately supervised,


5. any individual seeking  to make enquiries about handling personal information has access to the Data Protection Officer


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,


9. methods of handling personal information are regularly assessed and evaluated,


10. performance with handling personal information is regularly assessed and evaluated,


11. a breach of the rules and procedures identified in this policy by a member of staff may lead to disciplinary action being taken,


12. a breach of the rules and procedures identified in this policy by an employee or other individual  contracted to the company and responsible for managing and handling personal information is a potential breach of the Code of Conduct.




This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998.



NDF Associates

Data Protection Registration Number Z9322840


 NDF Associates Limited is registered in England.         Company No 5316759.                 Registered Office :- 2 Woodside Mews, Leeds LS16 6QE