1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE PROCESS ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• "Identity Data" includes first name, last name, username or similar identifier, title.
• "Contact Data" includes billing address, delivery address, email address and telephone numbers.
• "Financial Data" includes payment card details. • "Transaction Data" includes details about payments to and from you and other details of services you have purchased from us.
• "Technical Data" includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• "Profile Data" includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• "Usage Data" includes information about how you use our website, services.
• "Marketing and Communications Data" includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any "Special Categories of Personal Data" about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Your duty to inform us of changes It is important that the personal data we hold about you is accurate and current. Please keep the controller informed if your personal data changes during your relationship with us. If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with the controller, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with the controller (for example, to provide services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
• Direct interactions.
You or a controller / registered user may give us Identity, Contact and Financial Data for you and others by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you or a controller / registered user provide when they:
• apply for, or use, our services;
• become a registered user or create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you; • give us feedback or contact us.
• Automated technologies or interactions.
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties including technical data from analytics providers such as Google and search engine providers; identity and contact data from public sources such as Companies House and data brokers; all of whom may be inside or outside the UK and EU.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation. Generally, we do not rely on consent as a legal basis for processing your personal data.
You have the right to withdraw consent to marketing at any time by contacting us. Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity:To register you as a new client or registered user or to provide information to others (including the arbitral tribunal and opponent in an arbitration) for the purposes of undertaking a conflict check or establishing whether the appearance of bias exists||Type of data:(a) Identity (b) Contact||Lawful basis for processing including basis of legitimate interest:Performance of a contract|
|Purpose/Activity:To provide our services to you or any registered user including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us.||Type of data:(a) Identity (b) Contact (c) Financial d) Transaction (e) Marketing and Communications||Lawful basis for processing including basis of legitimate interest:(a) Performance of a contract (b) Necessary for our legitimate interests (to recover debts due to us)|
|Purpose/Activity:To provide our services to you or any registered user including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us.||Type of data: (a) Identity b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract (b) Necessary for our legitimate interests (to recover debts due to us)|
|Type of data: (a) Identity b) Contact(c) Profile (d) Marketing and Communications||Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract (b) Necessary to comply with a legal obligation c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/services)|
|Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Type of data: (a) Identity (b) Contact (c) Technical||Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|Purpose/Activity: To deliver relevant website content and measure or understand the effectiveness of the service we provide||Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|Purpose/Activity: To use data analytics to improve our website, products/services, marketing, client relationships and experiences||Type of data: (a) Technical (b) Usage||Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|Purpose/Activity: To make suggestions and recommendations to you about services that may be of interest to you||Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications||Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)|
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.
This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products from us and you have not opted out of receiving that marketing.
Third-party marketing We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of use of the site.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above.
• Internal Third Parties.
• External Third Parties.
• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or controllers who require reporting of processing activities in certain circumstances.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the UK or the European Economic Area.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, the perceived benefit of retention and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes. In some circumstances you can ask us to delete your data: see your legal rights below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. In particular, you have the right to: "Request access" to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. "Request correction" of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. "Request erasure" of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. "Object to processing" of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. "Request restriction of processing" of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. "Request the transfer" of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. "Withdraw consent at any time" where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us as above. No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we could refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
In order to improve our website, we may use small files commonly known as "cookies". A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (your "device") from our website and is stored on your device's browser or hard drive. The cookies we use on our website won't collect personally identifiable information about you and we won't disclose information stored in cookies that we place on your device to third parties.
You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.
We only use "Google Analytics" on our website. This cookie provides us with a visitor count and an understanding of how visitors move around and use the website. We can then use this information to improve navigability and our website generally. The cookies we use on our website won't collect personally identifiable information about you and we won't disclose information stored in cookies that we place on your device to third parties.
We are obliged by Google analytics to state the following:
Data Processing Addendum
This Data Processing Addendum ("Addendum") supplements the Agreement between CONFLICT CHECK LTD ("CONFLICT CHECK LTD") and the client as defined in the Agreement ("Client") (each a "Party" and collectively, the "Parties").
• The terms "process/processing", "data subject", "data processor", "data controller", "personal data", "personal data breach", and "data protection impact assessment" shall have the same meaning as in the GDPR;
• "Client Personal Data" means personal data received by CONFLICT CHECK LTD from or on behalf of the Client in connection with the performance of CONFLICT CHECK LTD's obligations under the Agreement and this Addendum;
• "Data Protection Laws" means any applicable law relating to the processing, privacy and/or use of personal data, as applicable to either party or the Services, including: (i) the General Data Protection Regulation (EU) 2016/679 ("GDPR"); (ii) the Data Protection Act 2018;(iii) any laws which implement any such laws; (iv) any laws that replace, extend, re-enact, consolidate or amend any of the foregoing;
• "Data Subject Request" means a request made by a data subject to exercise any rights of the data subject under Chapter III of the GDPR (and any similar obligations under applicable Data Protection Laws) in respect of Client Personal Data;
• "EEA" means the European Economic Area;
• "Services" means the services described in the Agreement;
• "Sub-processor" means any data processor appointed by CONFLICT CHECK LTD to process Client Personal Data on behalf of the Client;
• "Supervisory Authority" means (a) an independent public authority which is established by a Member State pursuant to the GDPR; and (b) any similar regulatory authority responsible for the enforcement of Data Protection Laws.
2. APPLICATION AND ROLE OF PARTIES
• This Addendum shall apply only to the extent that CONFLICT CHECK LTD carries out processing on Client's or a registered user's behalf of Client Personal Data to which the GDPR applies by virtue of Article 3 GDPR.
• The Parties agree that the Client is a data controller and CONFLICT CHECK LTD is a data processor for the purposes of processing Client Personal Data.
• Each Party shall at all times comply with its respective obligations under Data Protection Laws in connection with the processing of Client Personal Data.
3. PROCESSOR RESPONSIBILITIES
• CONFLICT CHECK LTD shall only process the Client Personal Data for the purposes of and in accordance with the terms of the Agreement and this Addendum, or otherwise in accordance with the Client's documented instructions from time to time, unless otherwise required by applicable law.
• The Client instructs CONFLICT CHECK LTD to process Client Personal Data in accordance with Schedule 1 (Details of Processing of Client Personal Data) and this Addendum, as reasonably required to perform the Services.
• If applicable law requires CONFLICT CHECK LTD to process Client Personal Data other than in accordance with the Client's documented instructions, CONFLICT CHECK LTD will notify the Client of any such requirement before processing, unless applicable law prevents it from doing so on grounds of public interest.
• CONFLICT CHECK LTD shall treat all Client Personal Data as confidential and shall inform its employees, agents, contractors and/or Sub-processors engaged in processing the Client Personal Data of the confidential nature of the Client Personal Data.
• CONFLICT CHECK LTD shall ensure that all such persons or parties involved in the processing of Client Personal Data are subject to confidentiality undertakings or are under an appropriate statutory obligation of confidentiality.
CONFLICT CHECK LTD shall implement and maintain appropriate technical and organisational measures as set out in Schedule 2 to this Addendum, to ensure a level of security of the Client Personal Data appropriate to the risks that are presented by the processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Client Personal Data transmitted, stored or otherwise processed, and shall take all measures required pursuant to Article 32 GDPR.
• The Client authorises CONFLICT CHECK LTD to engage Sub-processors in connection with the Services subject to the conditions set out in this section 6.
• CONFLICT CHECK LTD shall use only Sub-processors providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of Data Protection Laws and this Addendum and ensure the protection of the rights of data subjects.
• CONFLICT CHECK LTD shall notify Client in writing of any intended changes concerning the addition or replacement of Sub-processors, thereby giving the Client the opportunity to object to such changes.
• If the Client does not object to the proposed Sub-processor within 7 days of receipt of such notice, the Client shall be deemed to have accepted such Sub-processor. If, within 7 days of receipt of such notice, the Client raises reasonable objections to such Sub-processor, CONFLICT CHECK LTD shall take reasonably commercial steps to address the objections raised. If the Parties fail to agree on a solution within 10 days, the Client shall have the right to terminate the contract upon 30 days written notice.
• With respect to each Sub-processor, CONFLICT CHECK LTD shall:
› ensure that the arrangement between CONFLICT CHECK LTD and the Sub-processor is governed by a written contract including substantially similar
terms as those set out in this Addendum and which meets the requirements of Article 28(3) GDPR; and
› remain fully liable to the Client for any failure by each Sub-processor to fulfil its obligations in relation to the processing of any Client Personal Data.
7. ASSISTANCE WITH CLIENT'S COMPLIANCE AND DATA SUBJECT RIGHTS
• CONFLICT CHECK LTD shall refer all Data Subject Requests it receives to the Client without undue delay, and in any event, within three (3) business days of receipt of the request.
• CONFLICT CHECK LTD shall, taking into account the nature of the processing, assist the Client by appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of the Client's obligation to respond to a Data Subject Request under Data Protection Laws.
• CONFLICT CHECK LTD shall provide to the Client such assistance as the Client reasonably requires (taking into account the nature of processing and the information available to CONFLICT CHECK LTD) to ensure compliance with the Client's obligations under Data Protection Laws with respect to:
› security of processing;
› data protection impact assessments; o prior consultation with a Supervisory Authority regarding high risk processing; and
› notifications to the Supervisory Authority and/or communications to data subjects by the Client in response to any personal data breach involving Client Personal Data, provided the Client shall pay CONFLICT CHECK LTD's reasonable costs for providing the assistance in this section, such costs to be calculated at £250 per hour of the time of CONFLICT CHECK LTD directors and staff and the actual cost of third parties.
8. INCIDENT MANAGEMENT
• In the case of a personal data breach involving Client Personal Data, CONFLICT CHECK LTD shall immediately and, where feasible, not later than 48 hours after having become aware of it, notify such personal data breach to the Client and providing the Client with sufficient information to enable the Client to meet any obligations to report the breach under Data Protection Laws. Such notification shall as a minimum:
› describe the nature of the personal data breach, the categories and numbers of data subjects concerned, and the categories and numbers of personal data records concerned; o communicate the name and contact details of CONFLICT CHECK LTD's data privacy manager or other relevant contact from whom more information may be obtained;
› describe the likely consequences of the personal data breach; and o describe the measures taken or proposed to be taken to address the data breach, including, where appropriate, measures to mitigate its possible adverse effects.
• CONFLICT CHECK LTD shall co-operate with the Client, as reasonably required, and take such reasonable commercial steps to assist in the investigation, mitigation and remediation of a personal data breach involving Client Personal Data.
• The obligations described in section 8 shall not apply in the event that such personal data breach results from the actions or omissions of the Client.
CONFLICT CHECK LTD's obligation to report or respond to a personal data breach under section 8 will not be construed as an acknowledgment by CONFLICT CHECK LTD of any fault or liability with respect to such personal data breach.
9. DELETION OR RETURN OF CLIENT PERSONAL DATA
On cessation of the provision of the Services relating to the processing of Client Personal Data, at the Client's reasonable cost and the Client's option, CONFLICT CHECK LTD shall either return the Client Personal Data to the Client or securely dispose of the Client Personal Data (and thereafter delete all existing copies of it) except to the extent that any applicable law requires CONFLICT CHECK LTD to store such Client Personal Data.
10. AUDIT RIGHTS
• CONFLICT CHECK LTD shall, in accordance with Data Protection Laws, make available to the Client such information as is reasonably necessary to demonstrate CONFLICT CHECK LTD's compliance with its obligations under Data Protection Laws, and allow for and contribute to audits, including inspections, by the Client (or another auditor mandated by the Client) for this purpose, subject to the Client:
› giving CONFLICT CHECK LTD reasonable prior notice of such information request, audit and/or inspection being required by the Client; o ensuring that all information obtained or generated by the Client or its auditor(s) in connection with such information requests, inspections and audits is kept strictly confidential (save for disclosure to the Supervisory Authority or as otherwise required by applicable law);
› ensuring that such audit or inspection is undertaken during normal business hours, with minimal disruption to CONFLICT CHECK LTD's business; and o paying CONFLICT CHECK LTD's reasonable costs for assisting with the provision of information and allowing for and contributing to inspections and audits.
11. INTERNATIONAL DATA TRANSFERS
CONFLICT CHECK LTD shall not transfer Client Personal Data outside of the UK or the EEA except in accordance with the Client's documented instructions (whether in the Services Agreement, this Addendum or otherwise).
The Parties may agree to amend or supplement this Addendum, after giving prior written notice to the other party, if and to the extent necessary to comply with Data Protection Laws or the requirement of any supervisory, regulatory or governmental authority; or to comply with any code of conduct approved under the GDPR. 13. MISCELLANEOUS
• The disclaimers, liability exclusions and limitations of liability set out under the Terms and Conditions shall apply also to this Addendum.
• Any obligation imposed on CONFLICT CHECK LTD under this Addendum in relation to the processing of Client Personal Data shall survive any termination or expiration of the Services Agreement.
• With regard to the subject matter of this Addendum, in the event of any conflict or inconsistency between any provision of the Terms and Conditions and any provision of this Addendum, the provision of this Addendum shall prevail.
Details of Processing of Client Personal Data Under Data Protection Laws, CONFLICT CHECK LTD shall only process Client Personal Data in accordance with Client's documented instructions, as set out herein. The Client's instructions may be amended in writing by the Client from time to time, as communicated in writing to CONFLICT CHECK LTD by an authorised representative of the Client or through the Client's use of the Service.
SUBJECT MATTER OF PROCESSING
CONFLICT CHECK LTD shall process Client Personal Data only within the scope of the provision of the Services.
PURPOSE OF PROCESSING.
CONFLICT CHECK LTD shall process Client Personal Data only for the purpose of providing the Services.
CATEGORIES OF DATA SUBJECTS AND TYPES OF PERSONAL DATA
The Client Personal Data pertains to the information recorded on the site.
SPECIAL CATEGORIES OF PERSONAL DATA
The Client shall not provide to CONFLICT CHECK LTD any Client Personal Data that falls into any of the special categories of data (as set out in the GDPR) without CONFLICT CHECK LTD's prior written consent.
CONFLICT CHECK LTD engages in various activities as required for the provision of support and professional services. The Client Personal Data is stored and processed as needed to adequately ensure an acceptable level of performance in relation to maintenance and support contracts. The Client Personal Data is accessed, read, and utilized as necessary throughout the life of the contract. If the contract terminates, the Client Personal Data is destroyed in accordance with this Addendum.
DURATION OF PROCESSING
Client Personal Data shall not be processed for a period longer than is necessary for the purposes of collecting it. The duration of processing shall be for the Term of the Services Agreement, and any period beyond the Term in accordance with [Peter Ashford Co]'s [Data Retention Policy], to the extent that any applicable law requires [Peter Ashford Co] to store such Client Personal Data.
CONFLICT CHECK LTD has not engaged any Sub-processor(s) as at the date of the Terms and Conditionsfor carrying out processing activities on behalf of the Client.
INTERNATIONAL DATA TRANSFERS
Technical and Organisational Measures
In accordance with the Data Protection Laws, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing of the Protected Data to be carried out under or in connection with this Agreement, as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons and the risks that are presented by the processing, especially from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to the Protected Data transmitted, stored or otherwise processed, the Supplier shall implement appropriate technical and organisational security measures appropriate to the risk, including as appropriate those matters mentioned in Articles 32(1)(a) to 32(1)(d) (inclusive) of the GDPR.