SEKYEE COMPUTER LTD – DATA PROTECTION POLICY

5th January 2018
This Policy sets out the obligations of Sekyee Computer Limited, a company registered in England
under number 3494037, whose registered office is at 173 Junction Road, London, N19 5PZ (“the
Company”) regarding data protection and the rights of customers, suppliers, contractors and
employees thereof (“data subjects”) in respect of their personal data under EU Regulation 2016/679
General Data Protection Regulation (“GDPR”). The 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.
2. The Data Protection Principles
This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles
with which any party handling personal data must comply. All personal data must be:
2.1 Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
2.2 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.
2.3 Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is
processed.
2.4 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.
2.5 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 GDPR in order to
safeguard the rights and freedoms of the data subject.
2.6 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.
3. The Rights of Data Subjects
The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this
policy indicated for further details):
3.1 The right to be informed (Part 12).
3.2 The right of access (Part 13);
3.3 The right to rectification (Part 14);
3.4 The right to erasure (also known as the ‘right to be forgotten’) (Part 15);
3.5 The right to restrict processing (Part 16);
3.6 The right to data portability (Part 17);
3.7 The right to object (Part 18)
4. Lawful, Fair, and Transparent Data Processing
4.1 The 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:
4.1.1 The data subject has given consent to the processing of their personal data for one or more
specific purposes;
4.1.2 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;
4.1.3 The processing is necessary for compliance with a legal obligation to which the data controller
is subject;
4.1.4 The processing is necessary to protect the vital interests of the data subject or of another
natural person;
4.1.5 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
4.1.6 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.
4.2 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:
4.2.1 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);
4.2.2 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 (insofar as it is authorised by EU or EU Member State law or a collective
agreement pursuant to EU Member State law which provides for appropriate safeguards for the
fundamental rights and interests of the data subject);
4.2.3 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;
4.2.4 The data controller is a foundation, association, or other non-profit body with a political,
philosophical, religious, or trade union aim, and the processing is carried out in the course of its
legitimate activities, provided that the processing relates solely to the members or former members
of that body or to persons who have regular contact with it in connection with its purposes and that
the personal data is not disclosed outside the body without the consent of the data subjects;
4.2.5 The processing relates to personal data which is clearly made public by the data subject;
4.2.6 The processing is necessary for the conduct of legal claims or whenever courts are acting in
their judicial capacity;
4.2.7 The processing is necessary for substantial public interest reasons, on the basis of EU or EU
Member State law which shall be proportionate to the aim pursued, shall respect the essence of the
right to data protection, and shall provide for suitable and specific measures to safeguard the
fundamental rights and interests of the data subject;
4.2.8 The processing is necessary for the purposes of preventative or occupational medicine, for the
assessment of the working capacity of an employee, for medical diagnosis, for the provision of
health or social care or treatment, or the management of health or social care systems or services on
the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject
to the conditions and safeguards referred to in Article 9(3) of the GDPR;
4.2.9 The processing is necessary for public interest reasons in the area of public health, for example,
protecting against serious cross-border threats to health or ensuring high standards of quality and
safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member
State law which provides for suitable and specific measures to safeguard the rights and freedoms of
the data subject (in particular, professional secrecy); or
4.2.10 The processing is necessary for archiving purposes in the public interest, scientific or historical
research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU
or EU Member State law which shall be proportionate to the aim pursued, respect the essence of
the right to data protection, and provide for suitable and specific measures to safeguard the
fundamental rights and the interests of the data subject.
5. Specified, Explicit, and Legitimate Purposes
5.1 The Company collects and processes the personal data set out in Part 21 of this Policy. This
includes:
5.1.1 Personal data collected directly from data subjects.
5.1.2 Personal data obtained from associated third parties.
5.2 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 GDPR).
5.3 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.
6. 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.
7. Accuracy of Data and Keeping Data Up-to-Date
7.1 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.
7.2 The accuracy of personal data shall be checked when it is collected and periodically 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.
8. Data Retention
8.1 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.
8.2 When personal data is no longer required, all reasonable steps will be taken to erase or
otherwise dispose of it without delay.
8.3 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.
9. 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 20 to 25 of this Policy
10. Accountability and Record-Keeping
10.1 The Company’s Data Protection Officer is Daniel Targain and contactable at the company
address.
10.2 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 GDPR and other applicable data protection legislation.
10.3 The Company shall keep written internal records of all personal data collection, holding, and
processing, which shall incorporate the following information:
10.3.1 The name and details of the Company, its Data Protection Officer, and any applicable thirdparty data processors;
10.3.2 The purposes for which the Company collects, holds, and processes personal data;
10.3.3 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;
10.3.4 Details of any transfers of personal data to non-EEA countries including all mechanisms and
security safeguards;
10.3.5 Details of how long personal data will be retained by the Company (please refer to the
Company’s Data Retention Policy); and
10.3.6 Detailed descriptions of all technical and organisational measures taken by the Company to
ensure the security of personal data..
11. Data Protection Impact Assessments
11.1 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 GDPR].
11.2 Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall
address the following:
11.2.1 The type(s) of personal data that will be collected, held, and processed;
11.2.2 The purpose(s) for which personal data is to be used;
11.2.3 The Company’s objectives;
11.2.4 How personal data is to be used;
11.2.5 The parties (internal and/or external) who are to be consulted;
11.2.6 The necessity and proportionality of the data processing with respect to the purpose(s) for
which it is being processed;
11.2.7 Risks posed to data subjects;
11.2.8 Risks posed both within and to the Company; and
11.2.9 Proposed measures to minimise and handle identified risks.
12. Keeping Data Subjects Informed
12.1 If it is not clear at the time of collection the Company can provide the information set out in
Part 12.2 to every data subject:
12.1.1 Where personal data is collected directly from data subjects, those data subjects will be
informed of its purpose at the time of collection; and
12.1.2 Where personal data is obtained from a third party, the relevant data subjects will be
informed of its purpose:
a) if the personal data is used to communicate with the data subject, when the first communication
is made; or b) if the personal data is to be transferred to another party, before that transfer is made;
or
c) as soon as reasonably possible and in any event not more than one month after the personal data
is obtained.
12.2 If it is not clear at the time of collection the following information can be provided:
12.2.1 Details of the Company including, but not limited to, the identity of its Data Protection
Officer;
12.2.2 The purpose(s) for which the personal data is being collected and will be processed (as
detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;
12.2.3 Where applicable, the legitimate interests upon which the Company is justifying its collection
and processing of the personal data;
12.2.4 Where the personal data is not obtained directly from the data subject, the categories of
personal data collected and processed;
12.2.5 Where the personal data is to be transferred to one or more third parties, details of those
parties;
12.2.6 Where the personal data is to be transferred to a third party that is located outside of the
European Economic Area (the “EEA”), details of that transfer, including but not limited to the
safeguards in place (see Part 28 of this Policy for further details);
12.2.7 Details of data retention;
12.2.8 Details of the data subject’s rights under the GDPR;
12.2.9 Details of the data subject’s right to withdraw their consent to the Company’s processing of
their personal data at any time;
12.2.10 Details of the data subject’s right to complain to the Information Commissioner’s Office (the
“supervisory authority” under the GDPR);
12.2.11 Where applicable, details of any legal or contractual requirement or obligation necessitating
the collection and processing of the personal data and details of any consequences of failing to
provide it; and
12.2.12 Details of any automated decision-making or profiling that will take place using the personal
data, including information on how decisions will be made, the significance of those decisions, and
any consequences.
13. Data Subject Access
13.1 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.
13.2 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.
13.3 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. If such
additional time is required, the data subject shall be informed.
13.4 All SARs received shall be handled by the Company’s Data Protection Officer.
13.5 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, particularly where
such requests are repetitive.
14. Rectification of Personal Data
14.1 Data subjects have the right to require the Company to rectify any of their personal data that is
inaccurate or incomplete.
14.2 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. The period
can be extended by up to two months in the case of complex requests. If such additional time is
required, the data subject shall be informed.
14.3 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.
15. Erasure of Personal Data
15.1 Data subjects have the right to request that the Company erases the personal data it holds
about them in the following circumstances:
15.1.1 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;
15.1.2 The data subject wishes to withdraw their consent to the Company holding and processing
their personal data;
15.1.3 The data subject objects to the Company holding and processing their personal data (and
there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of
this Policy for further details concerning the right to object);
15.1.4 The personal data has been processed unlawfully;
15.1.5 The personal data needs to be erased in order for the Company to comply with a particular
legal obligation.
15.2 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. The period can be extended by up to two months in the case of
complex requests. If such additional time is required, the data subject shall be informed.
15.3 In the event that any personal data that is to be erased in response to a data subject’s request
has been disclosed to third parties, those parties shall be informed of the erasure (unless it is
impossible or would require disproportionate effort to do so).
16. Restriction of Personal Data Processing
16.1 Data subjects may request that the Company ceases processing the personal data it holds
about them. If a data subject makes such a request, the Company shall retain only the amount of
personal data concerning that data subject (if any) that is necessary to ensure that the personal data
in question is not processed further.
16.2 In the event that any affected personal data has been disclosed to third parties, those parties
shall be informed of the applicable restrictions on processing it (unless it is impossible or would
require disproportionate effort to do so).
17. Data Portability
17.1 The Company may process personal data using automated means.
17.2 Where data subjects have given their consent to the Company to process their personal data in
such a manner, or the processing is otherwise required for the performance of a contract between
the Company and the data subject, data subjects have the right, under the GDPR, to receive a copy
of their personal data and to use it for other purposes (namely transmitting it to other data
controllers).
17.3 Where technically feasible, if requested by a data subject, personal data shall be sent directly to
the required data controller.
17.4 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. If such additional time is required, the data subject shall be informed.
18. Objections to Personal Data Processing
18.1 Data subjects have the right to object to the Company processing their personal data based on
legitimate interests, direct marketing (including profiling).
18.2 Where a data subject objects to the Company processing their personal data based on its
legitimate interests, the Company shall cease such processing immediately, unless it can be
demonstrated that the Company’s legitimate grounds for such processing override the data subject’s
interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.
18.3 Where a data subject objects to the Company processing their personal data for direct
marketing purposes, the Company shall cease such processing immediately.
19. Personal Data Collected, Held, and Processed
The following personal data may be collected, held, and processed by the Company (for details of
data retention, please refer to the Company’s Data Retention Policy):

Type of Data Purpose of Data
Company Names General Accounting (purchase/sales invoicing) Supplying and Maintaining
Goods and Services and related communications.
Contact Names General Accounting (purchase/sales invoicing) Supplying and Maintaining
Goods and Services and related communications.
Business Addresses General Accounting (purchase/sales invoicing) Supplying and Maintaining
Goods and Services and related communications.
Email Addresses General Accounting (purchase/sales invoicing) Supplying and Maintaining
Goods and Services and related communications.
Phone Numbers General Accounting (purchase/sales invoicing) Supplying and Maintaining
Goods and Services and related communications.
Bank Account
Numbers/Sort Codes
General Accounting (purchase/sales invoicing) Supplying and Maintaining
Goods and Services and related communications.

20. 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:
20.1 All emails containing personal data are encrypted using SSL and/or TLS.
20.2 All emails containing personal data must be marked “confidential”;
20.3 Personal data may be transmitted over secure networks only; transmission over unsecured
networks is not permitted;
20.4 Personal data may not be transmitted over a wireless network if there is a wired alternative
that is reasonably practicable;
20.5 Where personal data is to be sent by facsimile transmission the recipient should be informed in
advance of the transmission and should be waiting by the fax machine to receive the data;
20.6 Where personal data is to be transferred in hardcopy form it should be passed directly to the
recipient or sent using recorded delivery postal and/or courier service.
21. Data Security – Storage
The Company shall ensure that the following measures are taken with respect to the storage of
personal data: 21.1 All electronic copies of personal data should be stored securely using passwords
and disk drive encryption;
21.2 All hardcopies of personal data, along with any electronic copies stored on physical, removable
media should be stored securely
21.3 All personal data stored electronically should be backed up daily. All backups should be
encrypted.
22. Data Security – Disposal
When any personal data is to be erased or otherwise disposed of for any reason (including where
copies have been made and are no longer needed), it should be securely deleted and disposed of.
For further information on the deletion and disposal of personal data, please refer to the Company’s
Data Retention Policy.
23. Data Security – Use of Personal Data
The Company shall ensure that the following measures are taken with respect to the use of personal
data:
23.1 No personal data may be transferred to any employees, agents, contractors, or other parties,
whether such parties are working on behalf of the Company or not, without the authorisation of
Daniel Targain or Joshua Kim
23.2 Personal data must be handled with care at all times and should not be left unattended or on
view to unauthorised employees, agents, sub-contractors, or other parties at any time;
23.3 If personal data is being viewed on a computer screen and the computer in question is to be left
unattended for any period of time, the user must lock the computer and screen before leaving it;
and
23.4 Where personal data held by the Company is used for marketing purposes, it shall be the
responsibility of Daniel Targain to ensure that the appropriate consent is obtained and that no data
subjects have opted out, whether directly or via a thirdparty service such as the TPS.
24. Data Security – IT Security
The Company shall ensure that the following measures are taken with respect to IT and information
security: 24.1 All passwords used to protect personal data should not use words or phrases that can
be easily guessed or otherwise compromised. All passwords must contain a combination of
uppercase and lowercase letters and numbers.
24.2 Under no circumstances should any passwords be written down or shared between agents,
contractors, or other parties working on behalf of the Company. If a password is forgotten, it must
be reset using the applicable method.
24.3 All software (including, but not limited to, applications and operating systems) shall be kept upto-date.
24.4 No software may be installed on any Company-owned computer or device without the prior
approval of the Daniel Targain
25. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection,
holding, and processing of personal data:
25.1 All employees, agents, contractors, or other parties working on behalf of the Company shall be
made fully aware of both their individual responsibilities and the Company’s responsibilities under
the GDPR and under this Policy, and shall be provided with a copy of this Policy;
25.2 Only employees, agents, sub-contractors, or other parties working on behalf of the Company
that need access to, and use of, personal data in order to carry out their assigned duties correctly
shall have access to personal data held by the Company;
25.3 All employees, agents, contractors, or other parties working on behalf of the Company handling
personal data will be appropriately trained to do so;
25.4 All employees, agents, contractors, or other parties working on behalf of the Company handling
personal data will be appropriately supervised;
25.5 All employees, agents, contractors, or other parties working on behalf of the Company handling
personal data shall be required and encouraged to exercise care, caution, and discretion when
discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
25.6 Methods of collecting, holding, and processing personal data shall be regularly evaluated and
reviewed;
25.7 All personal data held by the Company shall be reviewed periodically, as set out in the
Company’s Data Retention Policy;
25.8 The performance of those employees, agents, contractors, or other parties working on behalf of
the Company handling personal data shall be regularly evaluated and reviewed;
25.9 All agents, contractors, or other parties working on behalf of the Company handling personal
data must ensure that any and all of their employees who are involved in the processing of personal
data are held to the same conditions as those relevant employees of the Company arising out of this
Policy and the GDPR; and
25.10 Where any agent, contractor or other party working on behalf of the Company handling
personal data fails in their obligations under this Policy that party shall indemnify and hold harmless
the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of
that failure.
26. Transferring Personal Data to a Country Outside the EEA
26.1 The Company may from time to time transfer (‘transfer’ includes making available remotely)
personal data to countries outside of the EEA.
26.2 The transfer of personal data to a country outside of the EEA shall take place only if one or
more of the following applies:
26.2.1 The transfer is to a country, territory, or one or more specific sectors in that country (or an
international organisation), that the European Commission has determined ensures an adequate
level of protection for personal data;
26.2.2 The transfer is to a country (or international organisation) which provides appropriate
safeguards in the form of a legally binding agreement between public authorities or bodies; binding
corporate rules; standard data protection clauses adopted by the European Commission; compliance
with an approved code of conduct approved by a supervisory authority (e.g. the Information
Commissioner’s Office); certification under an approved certification mechanism (as provided for in
the GDPR); contractual clauses agreed and authorised by the competent supervisory authority; or
provisions inserted into administrative arrangements between public authorities or bodies
authorised by the competent supervisory authority.
26.2.3 The transfer is made with the informed consent of the relevant data subject(s);
26.2.4 The transfer is necessary for the performance of a contract between the data subject and the
Company (or for pre-contractual steps taken at the request of the data subject);
26.2.5 The transfer is necessary for important public interest reasons;
26.2.6 The transfer is necessary for the conduct of legal claims;
26.2.7 The transfer is necessary to protect the vital interests of the data subject or other individuals
where the data subject is physically or legally unable to give their consent; or
26.2.8 The transfer is made from a register that, under UK or EU law, is intended to provide
information to the public and which is open for access by the public in general or otherwise to those
who are able to show a legitimate interest in accessing the register.
27. Data Breach Notification
27.1 All personal data breaches must be reported immediately to the Company’s Data Protection
Officer.
27.2 If a personal data breach occurs and that breach is likely to result in a risk to the rights and
freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational
damage, or other significant social or economic damage), the Data Protection Officer must ensure
that the Information Commissioner’s Office is informed of the breach without delay, and in any
event, within 72 hours after having become aware of it.
27.3 In the event that a personal data breach is likely to result in a high risk (that is, a higher risk
than that described under Part 27.2) to the rights and freedoms of data subjects, the Data Protection
Officer must ensure that all affected data subjects are informed of the breach directly and without
undue delay.
27.4 Data breach notifications shall include the following information:
27.4.1 The categories and approximate number of data subjects concerned;
27.4.2 The categories and approximate number of personal data records concerned;
27.4.3 The name and contact details of the Company’s data protection officer (or other contact point
where more information can be obtained);
27.4.4 The likely consequences of the breach;
27.4.5 Details of the measures taken, or proposed to be taken, by the Company to address the
breach including, where appropriate, measures to mitigate its possible adverse effects.
28. Implementation of Policy This Policy shall be deemed effective as of 5th January 2018. No part of
this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this
date.
This Policy has been approved and authorised by:
Name: Daniel Targain
Position: Director
Date: 6th January 2018
Due for Review by: 5th January 2020