This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
This Policy applies to you if you visit an event promoted or organised by the Company purchase a ticket for one of our events, purchase one of our services, or user products or services, over the phone, online, through our mobile applications or otherwise by using our website or interacting with us on social media (our “Services”).
We will receive your personal data when you provide them to us yourself or when you use or purchase one or more of our Services.
We also receive personal data about you from third parties. Third parties who provide us with personal data about you include:
- ticket agents such as Ticketmaster and others, who transfer personal data to us when you purchase a ticket from them for one of our events;
- specialist market research companies, who provide us with additional personal data about you and your household; and
- Facebook Inc., who, if you have consented, transfer personal data to us when you register for one of our Services using your Facebook account.
- Any similar third parties who lawfully provide us with personal data
We will combine any personal data about you that we receive from you, from other companies, and from third parties.
- As necessary, to perform a contract with you, such as a contract to process an order from you for one or more of our Services including, where applicable, taking payment and carrying out fulfilment and delivery.
- As necessary, to comply with a legal obligation, for the following purposes:
- where you exercise your rights under data protection law and make requests; and
- to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity.
- As necessary, for our legitimate interests in providing the Services and ensuring they operate safely, securely and in a commercially suitable way which is tailored to your use and interests, for the following purposes:
- to provide you with the Services;
- to verify your identity for security purposes;
- to help us to ensure our customers are genuine and to prevent fraud;
- to ensure the security of our website, mobile application and other technology systems;
- for the good governance of our business, including keeping financial records, to allow us to pay suppliers and to charge, invoice or refund customers;
- to search credit reference agencies before we provide you with credit;
- by using CCTV, to prevent and detect crime and to keep people who visit and work at our events and festivals safe and secure;
- to record and investigate health and safety and other incidents which have happened or may have happened at one of our events or festivals;
- to manage access to specific areas at an event (for example, we will use lists of people and/or vehicles to allow us to manage access to backstage VIP or premium viewing areas);
- to provide your information about our Services, to contact you about administrative matters, and to manage and respond to any queries or complaints you make or any correspondence you send us;
- to help us to return lost property to its rightful owner;
- to process your competition entries and your survey or voting information;
- for the purpose of marketing our Services and goods and services from other companies, including sending marketing communications and, where applicable, processing your registration, creating custom marketing audiences on third-party websites such as Facebook, and profiling and automated decision-making relating to our marketing;
- to “geo-fence” marketing so that you receive marketing communications or see advertisements which are relevant to your location;
- to operate competitions, including notifying you if you have won, to confirm delivery of a prize or for other related purposes; and
- for market research and statistical analysis and to analyse the use of our Services so that we can improve them.
- Based on your consent, for the following purposes:
- to send you marketing communications.
- Based on your explicit consent, when you provide us with personal data about your health, for the following purposes:
- to provide you with tailored services (for example, a wheelchair accessible space or a sign language interpreter); and
- to help us investigate an incident which may have taken place at one of our events or festivals.
The Data Protection Principles
This Policy aims to ensure compliance with the Regulation. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:
- processed lawfully, fairly, and in a transparent manner in relation to the data subject;
- collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Lawful, Fair, and Transparent Data Processing
The Regulation seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The Regulation states that processing of personal data shall be lawful if at least one of the following applies:
- the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which the controller is subject;
- processing is necessary to protect the vital interests of the data subject or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
Processed for Specified, Explicit and Legitimate Purposes
4.1 The Company collects and processes the personal data set out in Part 21 of this Policy. This may include personal data received directly from data subjects (for example, contact details used when a data subject communicates with us) and data received from third parties (for example, Mailchimp.
4.2 The Company only processes personal data for the specific purposes set out in this Policy (or for other purposes expressly permitted by the Regulation).
5. Adequate, Relevant and Limited Data Processing
The Company will only collect and process personal data for and to the extent necessary for the specific purpose(s) informed to data subjects as under Part 4, above.
Accuracy of Data and Keeping Data Up To Date
The Company shall ensure that all personal data collected and processed is kept accurate and up-to-date. The accuracy of data shall be checked when it is collected and at regular intervals thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.
The Company shall not keep personal data for any longer than is necessary in light of the purposes for which that data was originally collected and processed. When the data is no longer required, all reasonable steps will be taken to erase it without delay.
The Company shall ensure that all personal data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. Further details of the data protection and organisational measures which shall be taken are provided in Parts 22 and 23 of this Policy.
9.1 The Company’s data protection officer is Christopher Egelstaff firstname.lastname@example.org
9.2 The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
- The name and details of the Company, its data protection officer, and any applicable third party data controllers;
- The purposes for which the Company processes personal data;
- Details of the categories of personal data collected, held, and processed by the Company; and the categories of data subject to which that personal data relates;
- Details (and categories) of any third parties that will receive personal data from the Company;
- Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
- Details of how long personal data will be retained by the Company; and
- Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.
Privacy Impact Assessments
The Company shall carry out Privacy Impact Assessments when and as required under the Regulation. Privacy Impact Assessments shall be overseen by the Company’s data protection officer and shall address the following areas of importance:
10.1 The purpose(s) for which personal data is being processed and the processing operations to be carried out on that data;
10.2 Details of the legitimate interests being pursued by the Company;
10.3 An assessment of the necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
10.4 An assessment of the risks posed to individual data subjects; and
10.5 Details of the measures in place to minimise and handle risks including safeguards, data security, and other measures and mechanisms to ensure the protection of personal data, sufficient to demonstrate compliance with the Regulation.
- The Rights of Data Subjects
The Regulation sets out the following rights applicable to data subjects:
- The right to be informed;
- The right of access;
- The right to rectification;
- The right to erasure (also known as the ‘right to be forgotten’);
- The right to restrict processing;
- The right to data portability;
- The right to object;
- Rights with respect to automated decision-making and profiling.
Keeping Data Subjects Informed
12.1 The Company shall ensure that the following information is provided to every data subject when personal data is collected:
- Details of the Company including, but not limited to, the identity of its Data Protection Officer;
- The purpose(s) for which the personal data is being collected and will be processed (as detailed in this Policy) and the legal basis justifying that collection and processing
- Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
- Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
- Where the personal data is to be transferred to one or more third parties, details of those parties;
- Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 24 of this Policy for further details concerning such third country data transfers);
- Details of the length of time the personal data will be held by the Company (or, where there is no predetermined period, details of how that length of time will be determined);
- Details of the data subject’s rights under the Regulation;
- Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
- Details of the data subject’s right to complain to the Information Commissioner’s Office (the ‘supervisory authority’ under the Regulation);
- Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it;
- Details of any automated decision-making that will take place using the personal data (including but not limited to profiling), including information on how decisions will be made, the significance of those decisions and any consequences.
12.2 The information set out above in Part 12.1 shall be provided to the data subject at the following applicable time:
12.2.1 Where the personal data is obtained from the data subject directly, at the time of collection;
12.2.2 Where the personal data is not obtained from the data subject directly (i.e. from another party):
- If the personal data is used to communicate with the data subject, at the time of the first communication; or
- If the personal data is to be disclosed to another party, before the personal data is disclosed; or
- In any event, not more than one month after the time at which the Company obtains the personal data.
Data Subject Access
13.1 A data subject may make a subject access request (“SAR”) at any time to find out more about the personal data which the Company holds about them. The Company is normally required to respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension).
13.2 All subject access requests received must be forwarded to the Company’s data protection officer.
13.3 The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
Rectification of Personal Data
14.1 If a data subject informs the Company that personal data held by the Company is inaccurate or incomplete, requesting that it be rectified, the personal data in question shall be rectified, and the data subject informed of that rectification, within one month of receipt the data subject’s notice (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
14.2 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification of that personal data.
Erasure of Personal Data
15.1 Data subjects may request that the Company erases the personal data it holds about them in the following circumstances:
- It is no longer necessary for the Company to hold that personal data with respect to the purpose for which it was originally collected or processed;
- The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
- The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so)
- The personal data has been processed unlawfully;
- The personal data is being held and processed for the purpose of providing information society services to a child.
- The personal data needs to be erased in order for the Company to comply with a particular legal obligation.
15.2 Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
15.3 In the event that any personal data that is to be erased in response to a data subject request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).
Restriction of Personal Data Processing
16.1 Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data pertaining to that data subject that is necessary to ensure that no further processing of their personal data takes place.
16.2 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).
Objections to Personal Data Processing
17.1 Data subjects have the right to object to the Company processing their personal data based on legitimate interests (including profiling), direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.
17.2 Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing forthwith, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights and freedoms; or the processing is necessary for the conduct of legal claims.
17.3 Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing forthwith.
17.4 Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Regulation, ‘demonstrate grounds relating to his or her particular situation’. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.
We will combine any personal data about you that we receive from you, from other companies in Our Group, and from third-parties in order to create marketing profiles.
Marketing profiles include personal data such as information about Services you have used or purchased previously, information about when you have visited one of our events or festivals in the past, demographic data and data from your social media profiles.
For example, we may analyse the personal data of people who have purchased tickets for a particular future event that we are promoting or organising and then compare them with other people in our database. If we identify people in our database who have similar personal data to the original purchasers, we may then target marketing about that event to the new people we have identified in our database, for example by sending direct marketing emails. We may conduct the profiling and send the direct marketing emails automatically.
We conduct these automated decision-making and profiling activities for our legitimate interests in providing the Services and ensuring they operate in a commercially suitable way which is tailored to your use and interests.
Where the Company uses personal data for profiling purposes, the following shall apply:
- Clear information explaining the profiling will be provided, including its significance and the likely consequences;
- Appropriate mathematical or statistical procedures will be used;
- Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
- All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling (see Parts 22 and 23 of this Policy for more details on data security).
The following personal data may be collected, held, and processed by the Company:
- Basic contact information including name, email address, telephone number, for the purpose of marketing and promotional correspondance to new and existing customers;
- Personal information, contact details, billing & banking details, business details, in order to place bookings and take payments from customers, or when soliciting services from suppliers;
- Personal contact information, banking information, employment records, and other sensitive information such as family and health circumstances, explicitly and strictly of those employed by the Company, kept in confidential, restricted-access Staff Records;
- Banking information and transaction records, when making sales, paying suppliers or for internal payroll.;
- CCTV live footage monitored and recorded, for crime prevention, maintaining the security of property and premises, for investigating crime and identification of persons of interest pertaining to legal or criminal investigation;
- information about any device you have used to access our Services or the websites or mobile applications of other companies or to access the public Wi-Fi service at our events (such as your device’s make and model, device identifier, operating system, browser, MAC address or IP address);
- information about the pages or sections you have visited on the website or mobile applications provided by us, including the pages or sections you visited, the website or mobile application you were referred from, and when you visited or used them;
- information about the Services we provide to you (including for example, what we have provided to you, when and where and, if applicable, how much you paid);
- information about transactions you make with other companies in connection with our events and festivals (including for example, what they have provided to you, when and where and, if applicable, how much you paid)
- location data (for example, if you use Wi-Fi or our mobile applications at one of our events or festivals, we will record the dates and times you attended and which parts of the building or festival site you visited);
- your account login details, including your user name and password;
- information you provide to us with when you contact us by phone, email, post, or when you communicate with us via social media;
- information you provide to us about your health (for example when you are buying tickets for wheelchair accessible spaces, when you request a sign language interpreter, or when we are investigating an accident which may have happened at one of our events or festivals);
- your vehicle registration number;
- CCTV images when you visit one of our events;
- information about electronic communications you receive from us, including whether that communication has been opened and if you have clicked on any links within that communication;
- answers you provide when you respond to competitions, votes and surveys;
- your identity, public profile, follows and likes from a social network such as Facebook (this may include your employment or education information if you include it in your public profile);
- information from specialist market research companies who provide us with additional personal data about you and your household such as income, number of children, occupation, social grade, home ownership status, the products and services you use or intend to use or purchase, and your interests; and
- other personal data which you may disclose to us when you use our Services at any time.
Data Protection Measures
The Company shall ensure that all its employees, agents, contractors, or other parties working on its behalf comply with the following when working with personal data:
- Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hardcopies should be shredded, and electronic copies should be deleted.
- Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
- Where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using registered mail or private courier;
- Where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using registered mail or private courier;
- No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from the data protection officer.
- All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet or similar;
- No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of the data protection officer
- Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;
- If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it;
- No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of the data protection officer and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary.
- All personal data stored electronically should be backed up with backups stored onsite.
- All electronic copies of personal data should be stored securely;;
- Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
- Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the data protection officer to ensure that no data subjects have added their details to any marketing preference databases including, but not limited to, the Telephone Preference Service, the Mail Preference Service, the Email Preference Service, and the Fax Preference Service. Such details should be checked regularly.
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
- All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;
- Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
- All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
- All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
- Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;
- The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
- All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;
- All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Regulation;
- Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
Transferring Personal Data to a Country Outside the EEA
23.1 The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.
23.2 The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:
- The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
- The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the Regulation); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
- The transfer is made with the informed consent of the relevant data subject(s);
- The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
- The transfer is necessary for important public interest reasons;
- The transfer is necessary for the conduct of legal claims;
- The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
- The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.
Data Breach Notification
24.1 All personal data breaches must be reported immediately to the Company’s data protection officer.
24.2 If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the data protection officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
24.3 In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 25.2) to the rights and freedoms of data subjects, the data protection officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
24.4 Data breach notifications shall include the following information:
- The categories and approximate number of data subjects concerned;
- The categories and approximate number of personal data records concerned;
- The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
- The likely consequences of the breach;
- Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.
Sharing your personal data
We will share your personal data with the data processors that help us to provide the Services.
Any data processors with whom we share your personal data are limited (by law and by contract) in their ability to use your personal data for any purpose other than to provide services for us.
If you have consented, we will share your personal data with other trusted third parties, for example the artists, promoters or sponsors we work with, so that they can use your personal data for marketing or promotional purposes by sending you information about related products or service that may be of interest to you.
We will also disclose your personal data to third parties in the following circumstances:
- if we sell or buy any assets, we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if we (or substantially all of our assets) are acquired by a third party, in which case personal data held by us will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
- to protect the rights, property, or safety of us, our customers or other persons. This may include exchanging personal data with other organisations for the purposes of fraud protection and credit risk reduction.
- If you win a competition, we may publicly post some of your data on our website or mobile application (for example acceptance of a prize may also require you (unless prohibited by law) to allow us to post publically some of your personal data such as on a winners page).
- We will collect and aggregate on an anonymous basis information about you, your spending and use of our Services with information about other users of the Services in order to identify trends (“Aggregated Data”). We may pass Aggregated Data to the third parties such as partners, to give them a better understanding of our business
- We will pass data to our ticketing software supplier
- We will pass data to Portsmouth City Council under our Service Level Agreement
Save as expressly detailed above in this section, we will never share, sell or rent any of your personal data to any third party without notifying you and/or obtaining your consent.
Implementation of Policy
This Policy shall be deemed effective as of 25th May 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.