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Automated decision making policy

Stergiou Limited ("We") provide safeguards for individuals against the risk that a potentially damaging decision is taken without human intervention.  We will continually identify whether any of our processing operations constitute automated decision making and consider whether we need to update procedures to deal with the requirements of the General Data Protection Regulations (the “GDPR”).

Under the GDPR you have the right not to be subject to a decision when:

  • it is based on automated processing; and
  • it produces a legal effect or a similarly significant effect on you.

 We will ensure that you are able to:

  • obtain human intervention;
  • express your point of view; and
  • obtain an explanation of the decision and challenge it.

The right does not apply if the decision:

  • is necessary for entering into or performance of a contract between us and the individual;
  • is authorised by law (e.g. for the purposes of fraud or tax evasion prevention); or
  • based on explicit consent.

Furthermore, the right does not apply when a decision does not have a legal or similarly significant effect on someone.

If you do wish to challenge an automated decision, you should contact our Director and privacy manager along with your contact details.

Stergiou Limited
Leonidas Stergiou 
admin@stergioultd.com
Suite A, 6 Honduras Street, London EC1Y 0TH, United Kingdom
+44 (0) 20 7504 1325

Profiling

‘Profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

When processing personal data for profiling purposes, we will ensure that appropriate safeguards are in place.

We will ensure processing is fair and transparent by providing upon request meaningful information about the logic involved, as well as the significance and the envisaged consequences.

We will use appropriate mathematical or statistical procedures for profiling, and we will implement appropriate technical and organisational measures to enable inaccuracies to be corrected and minimise the risk of errors.

We will secure personal data in a way that is proportionate to the risk to the interests and rights of the individual and prevents discriminatory effects.

We will ensure that automated decisions do not:

  1. concern a child; or

  2. be based on the processing of special categories of data unless:

(a) We have the explicit consent of the individual; or

(b) the processing is necessary for reasons of substantial public interest on the basis of EU / Member State law proportionate to the aim pursued, respect the essence of the right to data protection and provide suitable and specific measures to safeguard fundamental rights and the interests of the individual.

 

Version date: 20 May 2018