Data Protection Policy
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Data Protection Policy

 

4. PREMIER ROLES & RESPONSIBILITIES

 

For a full list of members for each group, please contact the DPO.

Premier Executive Committee

The Executive Group is responsible for review and approval of this Policy.

Premier Compliance Committee

The Compliance Committee is responsible for approval and execution of this Policy. Compliance Committee Members are selected by Premier’s Executive Group.

Premier Business Unit Managers

Premier has appointed Business Unit Managers (“BUM”) with local responsibility for data protection compliance for Personal Data processed in their area and within their teams.

Premier Data Protection Officer

Premier’s Data Protection Officer (“DPO”) is primarily responsible for advising on and assessing Premier’s compliance with data protection laws and GDPR and making recommendations to improve practice in this area. Further, the DPO acts as Premier’s primary point of contact for all data protection matters, including GDPR.

Premier Staff

All staff, including permanent staff, fixed term contractors and temporary workers must comply with the rules and policies made by Premier including this Policy, and from May 2018 GDPR whenever collecting and processing Personal Data held, as part of their role or activities carried out by or on behalf of Premier

Premier Consultants and Contractors

Third parties such as consultants, contractors or agents, undertaking work on behalf of Premier involving Personal Data, must adhere to Premier’s Policy, comply with data protection laws and from May 2018, the GDPR.

Provisions will be included in contracts with external providers to ensure compliance with this Policy, data protection laws and GDPR.

Responsibilities include:

  • Adding, amend and updating Personal Data – Premier Staff;
  • Deleting Personal Data – IT Administrator as instructed by DPO;
  • Responding to requests for rectification, erasure, restriction data portability, objection, automated decision making processes and profiling and withdrawal of consent – IT Administrator as instructed by DPO;
  • Reporting Personal Data breaches and/or dealing with complaints – Premier Compliance Committee.

 

5. PERSONAL DATA – COMPLIANCE WITH DATA PROTECTION LAWS, INCLUDING GDPR

 

  • Premier will implement and monitor annual completion of, mandatory data protection reinforcement for all staff. The content of such reinforcement will be reviewed annually; however, it may also issue additional procedures, guidance or instructions from time to time.
  • Premier reserves the right to correct any activities carried out by or on behalf of Premier that it deems not compliant with this Policy whenever necessary;
  • Premier will protect the security of Personal Data by maintaining, and monitoring compliance with Premier’s Information Security Policy and Information Classification Scheme;
  • Premier will maintain a Records Retention and Disposal Schedule setting the periods for which records containing Personal Data are to be retained;
  • Premier will enter into legally binding agreements and/or addenda with external bodies where those bodies are engaged to process Personal Data on Premier’s behalf;
  • Premier will implement adequacy arrangements where transferring any Personal Data coming from or going outside the European Union;
  • Premier will only disclose Personal Data to third parties such as sub-sub processors and other bodies such as central governments, police and institutions where there is a lawful basis for doing so and appropriate arrangements are in place with those parties; and
  • Premier will seek to ensure that Personal Data is shared across different Premier teams, business units and/or locations only if these have a legitimate business need for accessing that data.

 

6. PERSONAL DATA – COLLECTION, USAGE, TRANSFER & PROCESSING

 

In the course of Premier’s service offering, Personal Data from many different Individuals may be collected and processed for destination and immigration services purposes only. The legal bases we rely upon to offer these services to you are consent, legitimate interest, legal obligation, contractual obligation. Collection also includes Personal Data received straight from the Individual, a Data Controller, etc.

Personal Data may include, but is not limited to, name, gender, date of birth, address, email address, phone number, citizenship, passport information, educational background, employment history, etc.

We also receive Personal Data from third parties with whom we conduct business with, such as distributors, and other companies or organizations with whom we enter into agreements to support our business and operations.

Premier’s usage and processing of Personal Data will always be lawful and in addition to other provisions under this Policy, within one of the following legal conditions:

  • Required for an agreement, application, request for, with or on behalf of the Individual;
  • Mandatory in order for Premier to comply with a legal obligation;
  • Deemed as a vital interest (protecting someone’s life);
  • Essential for Premier to perform a task in the public interest, and the task has a clear basis in law;
  • Required for legitimate interests pursued by Premier, Premier’s staff, consultants and/or contractors, unless these are overridden by the interests, rights and freedoms of the Individual;
  • If none of the conditions above applies, the usage and/or processing will only be lawful if the Individual has given Consent.

Premier processes Personal Data for Premier’s services offering only, in both electronic and paper form. Personal Data can include – without limitation- information such as names, contact details, education or employment details.

Further, Special Categories of Personal Data may be requested, however this will only be for specific purposes explained to the Individual.

In the event Children’s Personal Data is required for Premier’s service offering, Premier will seek Consent and require this from the children’s parents or legal guardian.

 

7. PERSONAL DATA – DISCLOSURE & CONSENT

 

Premier may share data with third parties only where it pertains Premier’s service offering related to a specific Individual and where it has a legal basis to do so.

All Premier forms (whether electronic or paper-based) that gather Personal Data on an Individual contain a statement explaining the purpose of using and disclosing such Personal Data. This may require Consent from the Individual if there is not a lawful basis to share the data, however Premier will request such Consent at all times, including through application forms, notifications and other relevant means and documentation. Personal Data should not be obtained, held, used or disclosed unless the individual has given consent.

Only authorized and properly instructed Premier team members are allowed to disclose Personal Data. Premier will always keep records of Personal Data shared with a third party, which will include recording any exemptions which have been applied, and why they have been applied.

Consent can however, be withdrawn at any time and if withdrawn, the processing will stop. Individuals will be promptly informed of their right to withdraw Consent.

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