Leadership Advisers 2020
Data Protection Policy
GDPR means the General Data Protection Regulation.
Responsible Person means Johannes C. Seybold, CEO,
Leadership Advisers, Londoner Straße 22, 13349 Berlin,
Germany. T: +49 1575 8228015. E-Mail: office@leadership-
advisers.com. Register of Systems means a register of all
systems or contexts in which personal data is processed by
1. Data protection principles
Leadership Advisers is committed to processing data in
accordance with its responsibilities under the GDPR. Article 5
of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in
relation to individuals;
b. 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;
c. adequate, relevant and limited to what is necessary in
relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every
reasonable step must be taken to ensure that personal data
that are inaccurate, having regard to the purposes for which
they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects
for no longer than is necessary for the purposes for which the
personal data are 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 GDPR in order to safeguard the
rights and freedoms of individuals; and
f. 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
2. General provisions
a. This policy applies to all personal data processed by
b. The Responsible Person shall take responsibility for
Leadership Advisers’ ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.
3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and
transparent, Leadership Advisers shall maintain a Register of
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and
any such requests made to Leadership Advisers shall be dealt
with in a timely manner.
4. Lawful purposes
a. All data processed by Leadership Advisers must be done
on one of the following lawful bases: consent, contract, legal
obligation, vital interests, public task or legitimate interests.
b. Leadership Advisers shall note the appropriate lawful basis
in the Register of Systems.
c. Where consent is relied upon as a lawful basis for
processing data, evidence of opt-in consent shall be kept with
the personal data.
d. Where communications are sent to individuals based on
their consent, the option for the individual to revoke their
consent should be clearly available and systems should be in
place to ensure such revocation is reflected accurately in
Leadership Advisers’ systems.
5. Data minimisation
Leadership Advisers shall ensure that personal data are
adequate, relevant and limited to what is necessary in relation
to the purposes for which they are processed.
a. Leadership Advisers shall take reasonable steps to ensure
personal data is accurate.
b. Where necessary for the lawful basis on which data is
processed, steps shall be put in place to ensure that personal
data is kept up to date.
7. Archiving / removal
a. To ensure that personal data is kept for no longer than
necessary, Leadership Advisers shall put in place an archiving
policy for each area in which personal data is processed and
review this process annually.
b. The archiving policy shall consider what data should/must be
retained, for how long, and why.
a. Leadership Advisers shall ensure that personal data is
stored securely using modern software that is kept-up-to-date.
b. Access to personal data shall be limited to personnel who
need access and appropriate security should be in place to
avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely
such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be
In the event of a breach of security leading to the accidental or
unlawful destruction, loss, alteration, unauthorised disclosure
of, or access to, personal data, Leadership Advisers shall
promptly assess the risk to people’s rights and freedoms.
Last updated: 5 March 2020
END OF POLICY