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People Group Services Limited
Company Number: 11570329

Data Breach Notification Procedure

Purpose

This document defines the operational process for reporting and managing a personal data breach in compliance with UK GDPR.

What is a Data Breach

A personal data breach is defined as:

A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data.

Examples include:

Sending payroll information to the wrong person
Unauthorised access to contractor records
Lost laptop containing personal data
Cyber-attack exposing system databases

Immediate Action

If a data breach is suspected:

Stop the incident if possible
Secure the affected system
Preserve evidence
Report immediately

Reporting Timeline

Employees must report a suspected breach immediately.

The organisation must assess and, if required, notify the Information Commissioner's Office within 72 hours.

Internal Escalation

The following individuals must be notified:

Compliance Officer / Data Protection Lead
IT Security Lead
Senior Management

If the incident involves client data, the relevant client may also need to be notified.

Breach Assessment

The following factors are assessed:

Type of data involved
Number of individuals affected
Sensitivity of data
Likelihood of harm to individuals
Whether the data was encrypted

ICO Notification

If the breach poses risk to individuals, notification will include:

Nature of the breach
Categories of data affected
Approximate number of individuals impacted
Measures taken to mitigate damage

Notification to Individuals

Individuals will be notified where the breach may result in:

Identity theft
Financial loss
Confidentiality compromise

Notifications will explain:

What happened
What information was involved
Actions taken
Advice to protect themselves

Incident Register

All breaches must be recorded in the company’s Data Breach Register.

This record includes:

Date and time
Nature of breach
Investigation findings
Corrective actions

Declaration

This Policy is approved by the Board of Directors of: People Group Services Limited Company Number: 11570329

Last updated: 10th March 2026