In certain cases when processing personal data, RWP is a Data Controller, but in all cases when
processing data under instructions from our clients, we are acting as a Data Processor.
Examples of RWP as a Data Processor include when we provide specialist data processing, mail
production and document hosting for banking, government and SME clients or carry out processing in
relation to our Holmes Analytical Software service.
When acting as a Data Processor, RWP will only do so under contract which will include a Data
Processing Agreement that outlines our obligations and includes all clauses as required under Article
In most cases we will collect personal information directly from you when you contact us by phone,
email or any other channels such as in person at events. You may also contact us through our website
or send us a CV or complete a job application where relevant.
We do not usually collect personal data from third party sources. However, we may connect with
clients and contacts via social media networks e.g. LinkedIn. In those circumstances we may have
access to your publicly available details from that source. We do not download that data or integrate
it with our systems.
When you visit our website, we may automatically collect technical data about your computer
equipment, browsing actions and preferences. In order to ensure our website functions correctly we
must use certain necessary cookies. Any other tracking cookies will be based on you consenting to the
use of such cookies.
If you follow a link to another website from our website, we are not responsible for the cookies or
content of this third-party site. We advise you to read the Privacy Notice and cookies information on
any websites you visit.
All data processed by RWP is done so in line with the principles of data processing, these are:
- lawfulness, fairness and transparency – we will always process data lawfully and never
in a way that would not be expected. We will always be clear, open and honest about how
the data is used.
- purpose limitation – we will only use personal data for specific purposes which will be
- data minimisation – we will only collect the minimum amount of data required to carry
out our services.
- accuracy – will we always try to ensure the accuracy of data.
- storage limitation – we apply retention periods to all data.
- integrity and confidentiality – RWP have appropriate technical and organisational
measures in place to protect the data we collect, process and store.
- accountability – we are responsible for and will be able to demonstrate compliance with
the above principles.
As a Data Controller, RWP will determine the appropriate lawful basis for all processing of personal
data. Where we act as a Data Processor, it will be the obligation of the Data Controller to ensure a
clear lawful basis has been defined for the processing of personal data by RWP.
Below are examples only relating to RWP as a Data Controller: