Context and Overview

Introduction

Data Protection Policy

iGennix Limited (UKVITest)

Document Control

Document Title Data Protection Policy

Organisation iGennix Limited

Trading Name UKVITest

Version 2.0

Effective Date July 2026

Review Date July 2027

Approved By Chief Executive Officer

Policy Owner Chief Executive Officer

1. Purpose

iGennix Limited ("the Company"), trading as UKVITest, is committed to protecting the privacy and personal data of all individuals with whom it interacts. This includes candidates, customers, website users, employees, contractors, suppliers and business partners.

The Company recognises that personal data is a valuable asset and is committed to processing it lawfully, fairly, securely and transparently.

This policy establishes the standards and responsibilities for collecting, using, storing, sharing and disposing of personal data in accordance with:

UK General Data Protection Regulation (UK GDPR)

Data Protection Act 2018

Privacy and Electronic Communications Regulations (PECR)

Any other applicable UK data protection legislation

The policy also supports the Company's obligations under its Approved Service Provider Agreement with Trinity College London.

2. Scope

This policy applies to:

all directors of iGennix Limited

all employees

temporary staff

contractors

consultants

volunteers

anyone processing personal data on behalf of the Company

It applies to all personal data processed by the Company, regardless of whether that information is held electronically, on paper or in any other format.

3. Definitions

For the purpose of this policy:

Personal Data

Any information relating to an identified or identifiable living individual.

Examples include:

name

address

email address

telephone number

passport details

nationality

date of birth

IP address

online identifiers

payment information

correspondence

Processing

Any operation carried out on personal data including:

collection

recording

storage

organisation

retrieval

consultation

use

disclosure

transfer

deletion

destruction

Data Subject

The individual whose personal data is processed.

Data Controller

iGennix Limited acts as the Data Controller for personal data processed through UKVITest unless otherwise stated.

4. Data Protection Principles

iGennix Limited processes personal data in accordance with the seven principles contained within the UK GDPR.

Personal data shall be:

4.1 Lawfully, fairly and transparently processed

The Company will always ensure individuals understand why their information is collected and how it will be used.

4.2 Collected for specified, explicit and legitimate purposes

Personal data will only be collected for legitimate business purposes and will not be processed in a manner incompatible with those purposes.

4.3 Adequate, relevant and limited

Only the minimum amount of personal data necessary for the intended purpose will be collected.

4.4 Accurate and kept up to date

Reasonable steps will be taken to ensure personal information remains accurate and current.

Where inaccuracies are identified they will be corrected without undue delay.

4.5 Kept only as long as necessary

Personal data will only be retained for as long as required to fulfil legal, contractual or legitimate business purposes.

Secure disposal procedures will be followed once retention periods expire.

4.6 Processed securely

Appropriate technical and organisational measures will be implemented to protect personal data against:

unauthorised access

accidental loss

destruction

alteration

disclosure

cyber attack

4.7 Accountability

iGennix Limited accepts responsibility for demonstrating compliance with UK data protection legislation through documented policies, procedures and regular reviews.

5. Roles and Responsibilities

The Chief Executive Officer has overall responsibility for ensuring compliance with this policy and applicable data protection legislation.

Management is responsible for:

implementing appropriate procedures

ensuring staff understand their responsibilities

investigating data protection incidents

ensuring corrective actions are taken where necessary

Employees are responsible for:

protecting personal data

only accessing information required for their duties

maintaining confidentiality

reporting suspected data breaches immediately

following this policy at all times

6. Personal Data Collected

Depending upon the services provided, iGennix Limited may collect and process:

Full name

Residential address

Email address

Telephone number

Date of birth

Nationality

Passport details

Identification documents

Booking information

Payment information

Website usage information

IP addresses

Correspondence

Customer enquiries

The Company will only collect information that is necessary for legitimate business purposes.