Data Protection Policy

Context and overview


Catalyst Solutions BV trading as Appergine, hereafter Catalyst, needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees, website visitors and other people the organisation has a relationship with or may need to contact. Additionally, Catalyst may process certain information of individuals on behalf of its customers. This policy describes how these personal data are collected, handled and stored to meet the company’s data protection standards — and to comply with the law.


This data protection policy ensures Catalyst:

  • complies with data protection law and follows good practice;
  • protects the rights of staff, customers and partners;
  • is open about how it stores and processes personal data;
  • protects itself from risks like
    • breaches of confidentiality, for instance, the information being given out inappropriately;
    • failing to offer a choice, for instance, all individuals should be free to choose whether the company uses data relating to them;
    • reputational damage, for instance, the company could suffer if hackers successfully gained access to sensitive data.


The EU law ‘General Data Protection Regulation’ (GDPR) describes how organisations — including Catalyst — must collect, handle and store personal information.

The ‘General Data Protection Regulation’ is underpinned by the following principles, that state that personal data is:

  • processed fairly and lawfully;
  • obtained only for specific, lawful purposes;
  • adequate, relevant and not excessive;
  • accurate and kept up to date;
  • not held for any longer than necessary;
  • processed in accordance with the rights of data subjects;
  • protected in appropriate ways;
  • not transferred outside the European Economic Area (EEA), unless that country, territory or companies involved ensure an adequate level of protection, or appropriate legal contract is in place.

Responsibilities and guidelines


Everyone who works for or with Catalyst has the responsibility for ensuring data are collected, stored and handled appropriately. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles. However, the following people have key areas of responsibility, the:

  • Board of directors is ultimately responsible for ensuring that Catalyst meets its legal obligations;
  • Security Officer is responsible for:
    • keeping the board updated about data protection responsibilities, risks and issues;
    • reviewing all data protection procedures and related policies, in line with an agreed schedule;
    • arranging data protection training and advice for the people covered by this policy;
    • handling data protection questions from staff and anyone else covered by this policy;
    • dealing with requests from individuals to see the data Catalyst holds about them (also called ‘subject access requests’);
    • checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data;
  • Manager Operations is responsible for:
    • ensuring all systems, services and equipment used for storing data meet acceptable security standards;
    • performing regular checks and scans to ensure security hardware and software is functioning properly;
    • evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services;
  • The marketing manager is responsible for:
    • approving any data protection statements attached to communications such as emails and letters;
    • addressing any data protection queries from journalists or media outlets;
    • where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General staff guidelines

The general staff guidelines are as follows:

  • the only people able to access data covered by this policy should be those who need it for their work;
  • data should not be shared informally. When access to confidential information is required, employees can request it from their line managers;
  • Catalyst will provide training to all employees to help them understand their responsibilities when handling data;
  • employees should keep all data secure, by taking sensible precautions and following the guidelines below;
  • in particular, strong passwords must be used and they should never be shared;
  • personal data should not be disclosed to unauthorised people, either within the company or externally;
  • data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of;
  • employees should request help from their line manager or the Security Officer if they are unsure about any aspect of data protection.

Data handling

Data storage

These guidelines describe how and where data is safely stored.

When data is stored on paper:

  • it is kept in a secure place where unauthorised people cannot access it;
  • employees do not leave paper and printouts where unauthorised people could see them, for instance on a printer;
  • data printouts are shredded and disposed of securely when no longer required;

When data is stored electronically:

  • data is protected by strong passwords that are changed regularly and never shared between employees;
  • if data is stored on removable media, these are kept locked away securely when not being used.
  • data is only be stored on designated drives and servers, and is only uploaded to approved cloud computing services;
  • servers containing personal data are sited in a secure location, away from general office space;
  • data is backed up frequently. Those backups are tested regularly, in line with the company’s standard backup procedures;
  • data is not stored on laptops or other mobile devices like tablets or smartphones;
  • all servers and computers containing data are protected by approved security software and a firewall.

Data use

These guidelines describe how data is safely handled. When working with personal data, employees ensure that;

  • the screens of their computers are always locked when left unattended;
  • personal data is not shared informally;
  • personal data is never transferred outside of the European Economic Area or equivalently approved region unless an appropriate legal contract is in place;
  • they do not save copies of personal data to their own computers.

Data accuracy

The law requires Catalyst to take reasonable steps to ensure data is kept accurate and up to date. Catalyst ensures:

  • data will be held in a few places as necessary (i.e. staff does not create any unnecessary additional data sets);
  • data subjects are able to update the information Catalyst holds about them;
  • data is updated as inaccuracies are discovered.

Data collection and disclosure

Collecting data

Catalyst collects, manages and stores different kinds of personal data. The types of personal data can be split into three categories:

  1. Customer data – data about its customers (e.g. contacting details about the company and its contact persons);
  2. Employee data – data about its employees (e.g. names, addresses);
  3. Visitor data – data of visitors of its websites

The company has a Privacy policy, setting out how data relating to individuals is used by the company. This statement is available here.

Disclosing data for other reasons

Under certain circumstances, the GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Catalyst will disclose requested data. However, the Security Officer will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.