Data Retention Policy

Asima

Date: 22 August 2025

Introduction

This Policy sets out the obligations of Asima, a division of Wonderful Payments Limited, a company registered in England and Wales under number 07179973 regarding data protection and the rights of its customers, its suppliers, its employees and any other individual with whom a relationship requiring the sharing of personally identifiable information is established ("data subjects") in respect of their personal data under UK General Data Protection Regulation ("GDPR").

The UK GDPR defines "personal data" as any information relating to an identified or identifiable natural person (a "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets the Company's obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

The Data Protection Principles

This Policy aims to ensure compliance with the UK GDPR. The UK GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:

  1. Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
  2. 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.
  3. Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
  4. Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.
  5. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is 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 UK GDPR in order to safeguard the rights and freedoms of the data subject.
  6. 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 measures.

The Rights of Data Subjects

The UK GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):

  • The right to be informed (Part 12).
  • The right of access (Part 13);
  • The right to rectification (Part 14);
  • The right to erasure (also known as the 'right to be forgotten') (Part 15);
  • The right to restrict processing (Part 16);
  • The right to data portability (Part 17);
  • The right to object (Part 18); and
  • Rights with respect to automated decision-making and profiling (Parts 19 and 20).

Lawful, Fair, and Transparent Data Processing

The UK GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:

  1. The data subject has given consent to the processing of their personal data for one or more specific purposes;
  2. The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;
  3. The processing is necessary for compliance with a legal obligation to which the data controller is subject;
  4. The processing is necessary to protect the vital interests of the data subject or of another natural person;
  5. The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or
  6. The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Special Category Data

If the personal data in question is "special category data" (also known as "sensitive personal data") (for example, data concerning the data subject's race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:

  1. The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);
  2. The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law;
  3. The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
  4. The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim;
  5. The processing relates to personal data which is clearly made public by the data subject;
  6. The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;
  7. The processing is necessary for substantial public interest reasons;
  8. The processing is necessary for the purposes of preventative or occupational medicine;
  9. The processing is necessary for public interest reasons in the area of public health; or
  10. The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes.

Specified, Explicit, and Legitimate Purposes

The Company collects and processes the personal data set out in Part 21 of this Policy. This includes:

  • Personal data collected directly from data subjects; and
  • Personal data obtained from third parties.

The Company only collects, processes, and holds personal data for the specific purposes set out in Part 21 of this Policy (or for other purposes expressly permitted by the UK GDPR).

Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 12 for more information on keeping data subjects informed.

Adequate, Relevant, and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 5, above, and as set out in Part 21, below.

Accuracy of Data and Keeping Data Up-to-Date

The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 14, below.

The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

Data Retention

The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.

When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.

For full details of the Company's approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.

Secure Processing

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 22 to 27 of this Policy.

Accountability and Record-Keeping

The Company's Data Protection Officer, who can be contacted via Email: compliance@wonderful.co.uk.

The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company's other data protection-related policies, and with the UK GDPR and other applicable data protection legislation.

The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

  • The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;
  • The purposes for which the Company collects, holds, and processes personal data;
  • Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;
  • Details of any transfers of personal data to EEA and non-EEA countries including all mechanisms and security safeguards;
  • Details of how long personal data will be retained by the Company (please refer to the Company's Data Retention Policy); and
  • Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

Data Protection Impact Assessments

The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data which involve the use of new technologies and the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the UK GDPR.

Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:

  • The type(s) of personal data that will be collected, held, and processed;
  • The purpose(s) for which personal data is to be used;
  • The Company's objectives;
  • How personal data is to be used;
  • The parties (internal and/or external) who are to be consulted;
  • The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
  • Risks posed to data subjects;
  • Risks posed both within and to the Company; and
  • Proposed measures to minimise and handle identified risks.

Keeping Data Subjects Informed

The Company shall provide the information set out in Part 12.2 to every data subject:

  • Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and
  • Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose within specific timeframes as outlined in the policy.

The following information shall be provided:

  • Details of the Company including, but not limited to, the identity of its Data Protection Officer;
  • The purpose(s) for which the personal data is being collected and will be processed and the legal basis justifying that collection and processing;
  • Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
  • Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
  • Where the personal data is to be transferred to one or more third parties, details of those parties;
  • Details of data retention;
  • Details of the data subject's rights under the UK GDPR;
  • Details of the data subject's right to withdraw their consent;
  • Details of the data subject's right to complain to the Information Commissioner's Office; and
  • Details of any automated decision-making or profiling that will take place using the personal data.

Data Subject Access

Data subjects may make subject access requests ("SARs") at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.

Employees wishing to make a SAR should do so using a Subject Access Request Form, sending the form to the Company's Data Protection Officer at the details given in Part 10.1.

Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made.

The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive.

Rectification of Personal Data

Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.

The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue.

In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

Erasure of Personal Data

Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

  • It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
  • The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
  • The data subject objects to the Company holding and processing their personal data;
  • The personal data has been processed unlawfully;
  • The personal data needs to be erased in order for the Company to comply with a particular legal obligation.

Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject's request.

Data Portability

The Company processes personal data using automated means. Processes that involve automated data processing include; payroll, leave, absence and other such HR functions, call routing, billing, call data recording, all of which may contain personally identifiable information.

To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the following, encrypted formats:

  • PDF Documents,
  • CSV Files, and
  • Any other format deemed suitable and secure for the transmission of PII.

All requests for copies of personal data shall be complied with within one month of the data subject's request. The period can be extended by up to two months in the case of complex or numerous requests.

Automated Decision-Making

The Company does not use personal data in automated decision-making processes.

Profiling

The Company uses personal data for profiling purposes. Where a new business relationship is established, the Company may use personal information for identifying the commercial risk or any other associated risks to the Company and the prospective business.

When personal data is used for profiling purposes, the following shall apply:

  • Clear information explaining the profiling shall be provided to data subjects, including the significance and likely consequences of the profiling;
  • Appropriate mathematical or statistical procedures shall be used;
  • Technical and organisational measures shall be implemented to minimise the risk of errors;
  • All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

Data Security

Transferring Personal Data and Communications

The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

  • All emails containing personal data must be encrypted using PGP or an equivalent;
  • All emails containing personal data must be marked "confidential";
  • Personal data may be transmitted over secure networks only;
  • Personal data may not be transmitted over a wireless network if there is a wired alternative;
  • All personal data to be transferred physically shall be transferred in a suitable container marked "confidential".

Storage

The Company shall ensure that the following measures are taken with respect to the storage of personal data:

  • All electronic copies of personal data should be stored securely using passwords and data encryption to a standard no less than AES-XTS, AES-256 or equivalent;
  • All hardcopies of personal data should be stored securely in a locked box, drawer, cabinet, or similar;
  • All personal data stored electronically should be backed up every 28 days with backups stored onsite and offsite;
  • No personal data should be stored on any mobile device without formal written approval;
  • Personal data may only be transferred to devices belonging to third parties where they have agreed to comply with this Policy and GDPR requirements.

IT Security

The Company shall ensure that the following IT security measures are implemented:

  • All security-related software updates must be implemented as soon as they are made available;
  • All software must be upgraded or removed before vendor support ceases;
  • Hard disk encryption is required on any devices that hold Company data;
  • Strong passwords of at least 32 characters and two-factor authentication must be used;
  • Access details must be stored securely and transmitted via encrypted means only.

Transferring Personal Data Outside the UK

The Company may from time to time transfer personal data to countries outside of the UK. Such transfers shall only take place under specific conditions including adequate protection levels, appropriate safeguards, or explicit consent from data subjects.

Data Breach Notification

All personal data breaches must be reported immediately to the Company's Data Protection Officer.

If a personal data breach occurs and is likely to result in a risk to the rights and freedoms of data subjects, the Data Protection Officer must ensure that the Information Commissioner's Office is informed within 72 hours.

In cases of high risk to data subjects, all affected individuals must be informed directly and without undue delay.

Data breach notifications shall include:

  • The categories and approximate number of data subjects concerned;
  • The categories and approximate number of personal data records concerned;
  • Contact details of the Data Protection Officer;
  • The likely consequences of the breach;
  • Details of measures taken or proposed to address the breach.

Important: This Data Retention Policy is issued by Wonderful Payments Ltd, a company authorised by the FCA under the Payment Services Regulations 2017.