how we look after data:


Crecimiento Limited Data Protection policy


1. Aims

Crecimiento Limited aims to ensure that all personal data collected about clients and sub-contractors is collected, stored and processed in accordance with the General Data Protection Regulation (GDPR) and the expected provisions of the Data Protection Act 2018 (DPA 2018) as set out in the Data Protection Bill.

This policy applies to all personal data, regardless of whether it is in paper or electronic format. 


2. Legislation and guidance

This policy meets the requirements of the GDPR and the expected provisions of the DPA 2018. It is based on guidance published by the Information Commissioner’s Office (ICO) on the GDPR and the ICO’s code of practice for subject access requests.  


3. Definitions

Personal Data

Any information relating to an identified, or identifiable, individual.

This may include the individual’s: 

  • Name (including initials)

  • Identification number

  • Location data

  • Online identifier, such as a username

It may also include factors specific to the individual’s physical, physiological, genetic, mental, economic, cultural or social identity.

Special Categories of personal data

Personal data which is more sensitive and so needs more protection, including information about an individual’s:

  • Racial or ethnic origin

  • Political opinions

  • Religious or philosophical beliefs

  • Trade union membership

  • Genetics

  • Biometrics (such as fingerprints, retina and iris patterns), where used for identification purposes

  • Health – physical or mental

  • Sex life or sexual orientation


Anything done to personal data, such as collecting, recording, organising, structuring, storing, adapting, altering, retrieving, using, disseminating, erasing or destroying.   

Processing can be automated or manual. 

Data subject

The identified or identifiable individual whose personal data is held or processed.

Data controller

A person or organisation that determines the purposes and the means of processing of personal data.

Data processor

A person or other body, other than an employee of the data controller, who processes personal data on behalf of the data controller.

Personal data breach

A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data.

4. The data controller

Crecimiento Ltd processes personal data relating to clients and sub-contractors, and therefore is a data controller.

Crecimiento Ltd is registered as a data controller with the ICO and will renew this registration annually or as otherwise legally required.


5. Roles and responsibilities

The Company Director has overall responsibility for ensuring that Crecimiento Ltd complies with all relevant data protection obligations. This includes overseeing the implementation of this policy, monitoring compliance with data protection law, and developing related policies and guidelines where applicable.


6. Data protection principles

The GDPR is based on data protection principles that Crecimiento Ltd must comply with. 

The principles say that personal data must be:

  • Processed lawfully, fairly and in a transparent manner

  • Collected for specified, explicit and legitimate purposes

  • Adequate, relevant and limited to what is necessary to fulfil the purposes for which it is processed

  • Accurate and, where necessary, kept up to date

  • Kept for no longer than is necessary for the purposes for which it is processed

  • Processed in a way that ensures it is appropriately secure

This policy sets out how Crecimiento Ltd aims to comply with these principles.


7. Collecting personal data

7.1 Lawfulness, fairness and transparency 

Crecimiento Ltd will only process personal data where it has one of 6 ‘lawful bases’ (legal reasons) to do so under data protection law:

  • The data needs to be processed so that the company can fulfil a contract with the individual, or the individual has asked the company to take specific steps before entering into a contract

  • The data needs to be processed so that the company can comply with a legal obligation 

  • The data needs to be processed to ensure the vital interestsof the individual e.g. to protect someone’s life

  • The data needs to be processed so that the company can perform a task in the public interest,and carry out its official functions 

  • The data needs to be processed for the legitimate interests of the company or a third party (provided the individual’s rights and freedoms are not overridden)

  • The individual has freely given clear consent


Having considered the General Data Protection Regulation’s six bases for lawful processing, Crecimiento Limited is of the opinion that the data held by the company falls under Article 6 (1) (b) of the General Data Protection Regulation: “Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”.


7.2 Limitation, minimisation and accuracy

Crecimiento Ltd will only collect personal data for specified, explicit and legitimate reasons. The company will explain these reasons to the individuals when we first collect their data.

If the company wants to use personal data for reasons other than those given when first obtained, the company will inform the individuals concerned before doing so, and seek consent where necessary.

When the company no longer needs the personal data it holds, it must ensure it is deleted or anonymised. 


8. Sharing personal data

Crecimiento Ltd will not normally share personal data with anyone else. However, the company will share personal data with law enforcement and government bodies where it is legally required to do so, including for:


  • The prevention or detection of crime and/or fraud

  • The apprehension or prosecution of offenders

  • The assessment or collection of tax owed to HMRC

  • In connection with legal proceedings


The company may also share personal data with emergency services to help them to respond to an emergency situation that affects any of our clients or sub-contractors.

Where the company transfers personal data to a country or territory outside the European Economic Area, we will do so in accordance with data protection law.


9. Subject access requests and other rights of individuals

9.1 Subject access requests

Individuals have a right to make a ‘subject access request’ to gain access to personal information that Crecimiento Ltd holds about them. This includes:


  • Confirmation that their personal data is being processed

  • Access to a copy of the data

  • The purposes of the data processing

  • The categories of personal data concerned

  • Who the data has been, or will be, shared with

  • How long the data will be stored for, or if this isn’t possible, the criteria used to determine this period

  • The source of the data, if not the individual

  • Whether any automated decision-making is being applied to their data, and what the significance and consequences of this might be for the individual


Subject access requests must be submitted in writing, either by letter or email to the Company Director. They should include:


  • Name of individual

  • Correspondence address

  • Contact number and email address

  • Details of the information requested

If staff receive a subject access request they must immediately forward it to the DPO.


9.2 Responding to subject access requests

When responding to requests, Crecimiento Ltd

  • May ask the individual to provide 2 forms of identification

  • May contact the individual via phone to confirm the request was made 

  • Will respond without delay and within 1 month of receipt of the request

  • Will provide the information free of charge

  • May tell the individual we will comply within 3 months of receipt of the request, where a request is complex or numerous. We will inform the individual of this within 1 month, and explain why the extension is necessary


If the request is unfounded or excessive, we may refuse to act on it, or charge a reasonable fee which takes into account administrative costs.

A request will be deemed to be unfounded or excessive if it is repetitive, or asks for further copies of the same information. 

When we refuse a request, we will tell the individual why, and tell them they have the right to complain to the ICO.


9.3 Other data protection rights of the individual

In addition to the right to make a subject access request (see above), and to receive information when Crecimiento Ltd is collecting their data about how we use and process it (see section 7), individuals also have the right to:


  • Withdraw their consent to processing at any time

  • Ask us to rectify, erase or restrict processing of their personal data, or object to the processing of it (in certain circumstances)

  • Prevent use of their personal data for direct marketing

  • Challenge processing which has been justified on the basis of public interest

  • Request a copy of agreements under which their personal data is transferred outside of the European Economic Area

  • Object to decisions based solely on automated decision making or profiling (decisions taken with no human involvement, that might negatively affect them)

  • Prevent processing that is likely to cause damage or distress

  • Be notified of a data breach in certain circumstances

  • Make a complaint to the ICO

  • Ask for their personal data to be transferred to a third party in a structured, commonly used and machine-readable format (in certain circumstances)


Individuals should submit any request to exercise these rights to the Company Director.

10. Data protection by design and default

Crecimiento Ltd will put measures in place to show that we have integrated data protection into all of our data processing activities, including:

  • Only processing personal data that is necessary for each specific purpose of processing, and always in line with the data protection principles set out in relevant data protection law (see section 6)

  • Completing privacy impact assessments where the processing of personal data presents a high risk to rights and freedoms of individuals, and when introducing new technologies

  • Integrating data protection into internal documents including this policy, any related policies and privacy notices

  • Regularly conducting reviews and audits to test our privacy measures and make sure we are compliant

  • Maintaining records of our processing activities


11. Data security and storage of records

Crecimiento Ltd will protect personal data and keep it safe from unauthorised or unlawful access, alteration, processing or disclosure, and against accidental or unlawful loss, destruction or damage.


12. Disposal of records

Personal data that is no longer needed will be disposed of securely. Personal data that has become inaccurate or out of date will also be disposed of securely, where we cannot or do not need to rectify or update it.


13. Personal data breaches

Crecimiento Ltd will make all reasonable endeavours to ensure that there are no personal data breaches.  

In the unlikely event of a suspected data breach, we will follow the procedure set out in appendix 1.

When appropriate, we will report the data breach to the ICO within 72 hours. 

Privacy Notice

The categories of information that we collect, process, hold and share about clients include:

  • personal information (such as name, phone numbers, email address)

  • business-sensitive information

Why we collect and use this information

We use this data to:


  • facilitate effective communication

  • propose contractual arrangements

  • fulfil contractual obligations


The lawful basis on which we process this information

We process this information under Article 6 (1) (b) of the General Data Protection Regulation: “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.”


Storing this information

We hold clients’ data for 5 years


Who we share this information with

This information may be shared, with your consent, with subcontractors of the company.  We do not share information about clients with anyone without consent unless the law and our policies allow us to do so.

Requesting access to your personal data

Under data protection legislation, you have the right to request access to information about you that we hold. To make a request for your personal information, contact the Company Director.


You also have the right to:

  • object to processing of personal data that is likely to cause, or is causing, damage or distress

  • prevent processing for the purpose of direct marketing

  • object to decisions being taken by automated means

  • in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed; and

  • claim compensation for damages caused by a breach of the Data Protection regulations 


If you have a concern about the way we are collecting or using your personal data, we ask that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at


To help us manage our data effectively, and to ensure that we keep it for no longer than necessary, we have a Data Retention Schedule.  This outlines how long we will keep data.  The schedule can be viewed upon request to the Company Director.  The schedule will be reviewed on an ongoing basis in response to the needs of the company, and current legislation.