Our Policies

Payments, Refunds, Low Enrollment, Admission and Responsible Drinking

Payments in full are due at the time of registration for the course, payable through the website. Please contact us if you have circumstances that may preclude this, and we will attempt to make accommodations.

All courses are non-refundable, but you may transfer to another class up to three (3) weeks before the START of the course, and secure a spot in another course for no additional charge. All transfer requests must be received by email. Transfer requests received after this time will not be accepted.

Low Enrollment: On occasion we may have to cancel a class due to low enrollment or other circumstances. In the event that we cancel your class, you may transfer into the next session of class, space permitting, or you may receive a full credit or refund of the tuition, materials, and registration fees paid. If you transfer into a class that is more expensive than the cancelled one, you will be responsible for any difference in tuition or other fees. If the new class is less expensive, you may request a credit or refund of the difference. Students will be notified by email and telephone of the class cancellation.

Admission: All classes will involve the tasting of alcoholic beverages, so participants must be 21 years of age, and they should present identification on the first day of class.

Responsible Drinking: The class curriculum involves tasting alcoholic beverages and we strongly encourage spitting. In the event you feel you are not able to drive we will be happy to help you arrange transportation, at your own cost.

Policy for Candidates Requiring Reasonable Adjustments

A reasonable adjustment is any action that helps to reduce the effect of a disability or difficulty that places the candidate at a substantial disadvantage in the assessment situation.

This APP seeks to conduct the assessment of all candidates in a way that puts them at no disadvantage, or advantage, over other candidates. However, whilst Reasonable adjustments must not affect the integrity of what needs to be assessed, but may involve:

  • Changing standard assessment arrangements, for example allowing candidates extra time to complete the assessment activity

  • Adapting assessment materials, such as providing materials in large text format

  • Providing access facilitators during assessment, such as a sign language interpreter or reader

  • Re-organising the assessment room, such as removal of visual stimuli for an autistic candidate.

Reasonable adjustments are approved or set in place before the assessment activity takes place; they constitute an arrangement to give the candidate access to the qualification. The use of reasonable adjustment will not be taken into consideration during the assessment of a candidate’s work. Out of fairness to all candidates, evidence of the individual circumstances giving rise to the request must be produced.

Subvino will :

– identify any special assessment needs at the time of candidate registration.

– inform WSET® Awards at the earliest opportunity so that appropriate arrangements can be made.

– agree the specific arrangements for the examination, or for marking with WSET® Awards, which will vary according to individual circumstances.

WSET® Awards reserves the right to seek the advice of independent agencies as appropriate in coming to a decision on specific arrangements and must agree before any reasonable adjustments are offered by this APP to its students.

Please submit any Requests for Reasonable Adjustments at least 5 weeks before the date of the examination. This APP will forward any Requests for Reasonable Adjustments to WSET® Awards within 5 working days of receipt and WSET® Awards will respond after 4 working weeks after giving the request due consideration.

Candidates and their advisors should also be aware:

– that it is not appropriate to make requests for special arrangements where the candidate’s particular difficulty directly affects performance in the actual attributes that are the focus of the assessment.

– reasonable adjustments will not give unfair advantage over candidates for whom reasonable adjustments are not being made, or alter the assessment demands of the qualification as detailed in the qualification specificatio

Policy for Candidates Requiring Special Consideration

Special consideration is an action taken after an assessment to allow candidates who have been disadvantaged by temporary illness, injury, indisposition or adverse circumstances at the time of the assessment to demonstrate attainment.

A candidate may be eligible for special considerations if:

Performance in an examination is affected by circumstances beyond the control of the candidate.  This may include recent personal illness, accident, bereavement or examination room conditions;

alternative assessment arrangements which were agreed in advance of the assessment proved inappropriate or inadequate;

the application of special consideration would not mislead the end-user of the certificate.

WSET® Awards must be notified in writing within seven days of the examination date where special consideration is being requested. Please send a written request to us. Eligibility will only be considered if accompanied by supporting independent documentation, and please allow extra time for this APP to pass your request to WSET® Awards.

Where a candidate is unable to attend an examination due to recent personal illness, accident or bereavement, the APP will endeavour to transfer the candidate to an alternative examination date at no extra cost.

In cases of serious disruption during the examination, the Examinations Officer of this APP must submit a detailed report of the circumstances and candidates affected to the Examinations Administrator at WSET® Awards, in addition to the Examination Papers.

It should be noted that WSET® Awards does not offer aegrotat awards and that all assessment requirements of WSET® qualifications must be met.  It is also our policy that special considerations will not give unfair advantage over candidates for whom special considerations are not being applied, or alter the assessment demands of the qualification as detailed in the qualification specification.  Further guidance is available in Appendix 3  Guidance for Reasonable Adjustments and Special Considerations™.

If a candidate is unable to attend an examination for which they have been registered due to circumstances outside their direct control, they should notify this APP as soon as possible, and complete the Request for Special Consideration form submitting written 3rd party evidence to support their application.  Failure to attend due to work commitments does not qualify for Special Consideration.   This APP will not charge an unused paper fee for applications where approval from WSET® Awards is granted.


Malpractice and

Maladministration Policies

This APP will ensure that their program for the delivery and administration of any WSET qualification complies in all respects to the rules, regulations and procedures set out in the WSET APP Operating Handbook.  All WSET® examinations run by this APP will be administered in line with the Centre Agreement, Code of Practice and Invigilation Instructions provided in the Operating handbook, and Examination Regulations issued to all APPs and Students in the Qualification Specifications.  Failure to abide by these criteria will be considered Malpractice and or Maladministration and may affect our ability to continue teaching WSET qualifications.  Malpractice can arise from any act, omission, event, incident or circumstance that prejudices learners, affects public confidence in qualifications, affects the standards of qualifications which the awarding body makes available or affects the ability of the awarding body to undertake the development, delivery or award of qualifications. Maladministration relates to a failure by the APP to offer WSET Qualifications in accordance with the rules, regulations and operating procedures set out in this Handbook

Program Providers must have in place procedures for dealing with instances of Malpractice and Maladministration should they arise. These policies will be made available to WSET® Awards upon request, and form part of the criteria which must be met to become an APP.

The headings below list categories of maladministration by the staff of the APP and malpractice by APP staff and / or candidates which may adversely affect the integrity of WSET® qualifications and certification.  These examples are not exhaustive and are intended as guidance to APPs and their candidates on the WSETs definition of malpractice and maladministration.

Malpractice will include, but is not limited to:

Actual or attempted Plagiarism, or cheating, of any nature by candidates;

Use or attempted use of any reference material or electronic devise during a closed book examination

Disruptive behavior by candidates in the examination;

Candidates in breach of published Examination Regulations and APP in breach of invigilation rules or the Code of Conduct;

Fraudulent use of WSET® certificates;

A deliberate attempt to discredit the WSET®, or to bring the WSET® into disrepute in any way;

Issue of bogus examination results;

Insecure storage of examination papers;

Unauthorized amendment, copying or distribution of examination papers;

Use of unapproved or ineligible educators to deliver a qualification course, or use of un-authorized internal assessors

Change of examination location or altered facilities so they no longer meet the required standards;

Failure to administer examination in line with the assessment requirements;

Denial of access to resources (premises, records, information, candidates and staff) by authorized WSET® representatives and / or the Regulatory Authorities;

Maladministration will include, but is not limited to:

Failure to follow procedures or adhere to regulations as laid out in the APP Operating Handbook;

Failure to return examination papers within the required timeframe or

Returning exam papers by regular post and not recorded delivery or trackable courier;

Failure to issues results to candidates in a timely manner

Breach or infringement of WSET® copyright and trademarks;

Non-payment of fees for WSET® services or examinations;

Breach of the Conflicts of Interest Policy

Breach of the Centre Agreement or APP Code of Conduct;

A change in control of the APP that results in new management being unable to meet WSET® Awards criteria;

Malpractice is divided into two main categories;

Major Malpractice

Serious and /or deliberate breaches of conduct, or serious neglect of professional duty, represents a high risk to the integrity of the qualification.  Major Malpractice could result in the invalidation or revocation of examination results to a student and / or approval of the APP.  In this instance OfQual must be informed of the malpractice case and WSET® Awards will take all appropriate action as directed by the Regulatory Authority, which may include notification to other Awarding Bodies. An example of Major Malpractice would be, Fraudulent use of WSET® certificates and the issue of false examination results or Unauthorized amendment, copying or distribution of examination papers.

Minor Malpractice

Minor and /or accidental breaches of conduct or neglect of professional duty, or those more major breaches not considered to be deliberate or malicious in intent, represents a lower risk to the integrity of the qualification and would not affect examination results or certification.  Examples of minor malpractice could include, failure to follow procedures laid out in the Operating Handbook or Change of examination location or altered facilities so they no longer meet the required standards.

Reporting Malpractice

This APP will report any potential case of malpractice by candidates, educators, invigilators or centre staff to the Centers Co-ordinator and Quality Assurance Manager at WSET® Awards immediately using the Notification of Potential Malpractice Form.

Failure to do so may result in the refusal to issue results and Certification to candidates, the invalidation of examination results or the withdrawal of approval to offer WSET® qualifications.

Where APP personnel are involved, the APP should follow its own procedures and keep WSET® Awards informed of the steps taken to resolve the situation.

Malpractice may be reported to WSET® Awards by a WSET® Awards appointed Approval Visitor.  In this instance the APP will be advised during the approval visit that a case of Malpractice is being reported.

WSET® Awards will also act upon reports of suspected or actual malpractice received from candidates or other parties regarding an APPs activities or personnel which may affect the integrity of WSET® qualifications.

WSET® Awards responsibility

WSET® Awards will confirm receipt of a report of suspected or actual malpractice within 3 working days.

Should a case of malpractice be raised with WSET® Awards against the Program Provider, the main contact, or other appropriate person within the management of the APP, will be notified and invited to respond prior to further action being taken.  Notwithstanding the foregoing, WSET® Awards reserves the right to immediately suspend an APPs approval if, after consultation with the WSETs Chief Executive, it is decided that such a suspension is required to protect the reputation of the WSET, and to prevent any possible re-occurence of the alleged malpractice.  In such circumstances, the APP will be notified immediately and will be required to co-operate with the WSET® whilst the alleged malpractice is investigated.

WSET® Awards will appoint a suitably trained officer to investigate the alleged malpractice and this officer will request supporting evidence from the APP, Candidate or other parties to validate the report of suspected or actual malpractice.

When supporting evidence has been supplied, WSET® Awards will conduct a full investigation of the suspected or actual malpractice to identify the cause and to determine whether malpractice has actually occurred.

Where it is determined that malpractice has occurred, a report will be filed. This will include whether the malpractice is accidental or deliberate, and represents a major or minor threat to the integrity of the qualification, and specify any sanctions that are to be applied to the APP, their staff or the candidate concerned.  If malpractice has been alleged against a candidate, a summary of the investigation and the findings will be sent to the candidate; if the malpractice has been alleged against the APP the summary will be sent to the Main Contact, and the candidate or APP Main Contact will be advised of the sanctions being imposed.  They will also be advised of the General Appeals Policy should they wish to appeal the decision that has been made.

Any case of malpractice that threatens the integrity of the qualification, results issued or certification will be reported to the Regulatory Authority, and following discussion with the Regulatory Authority, other Awarding Bodies may be notified.

Where the report is the result of an internal investigation by the APP, WSET® Awards will review all the documentation supplied and action taken to ensure that any decisions made by the APP are valid and conform to this policy.  WSET® Awards may request additional information to determine whether any additional sanctions should be applied to the APP, their staff or the candidate concerned.

Our responsibility as the APP which we agree to carry out in full

The APP Main Contact is responsible for ensuring that all staff involved in the delivery and / or administration of the WSET® program run it in accordance with the rules, regulations and procedures set out in this manual, and are aware of, and comply with, this policy.  The APP must also establish their own framework of controls and checks that in their opinion is adequate to minimise and identify any instances of malpractice and is fit for purpose of reporting and investigating any alleged malpractice.  Should an APP require help in establishing a framework that will prevent, investigate and deal with Malpractice, please contact awards@wset.co.uk

The main Contact agrees to co-operate fully with WSET® Awards in any investigation of alleged malpractice at the APP including the removal and / or suspension of staff from their WSET® duties during such investigation.


In cases of alleged malpractice or maladministration WSET® Awards has the right to apply sanctions.  This may include suspend an APPs approval with immediate effect if such action is approved by the Chief Executive of the WSET® whilst an investigation is carried out.

Following an investigation by WSET® Awards, it may be necessary to apply one or more of the following sanctions against the APP and/or their staff.

Creation of an action plan / letter of warning;

Completion of a self-assessment form by the APP;

Completion of an APP re-approval visit (travel costs may be charged to the APP);

Mandatory re-training of educators and / or assessors;

Application of administration charges;

Withdrawal of internal assessment permissions;

Invalidation of examination results / certification;

Withdrawal or temporary suspension of approval to offer a specific WSET® qualification;

Withdrawal or temporary suspension of approval to offer all WSET® qualifications;

Withholding examination results that are under investigation;

Rejection of orders for further materials or examination papers;

Withdrawal of credit facilities, and moving account to a “cash on order” basis;

Charging of interest on overdue amounts.

Where previously agreed corrective measures are not implemented, the sanctions will progress to the next level of severity following the guidelines of the NVQ Code of Practice.

It is WSET Awards intent that no learner should be disadvantaged by any instance of malpractice or maladministration that has arisen by the actions (or non-action) of the APP.  However where such breach undermines the integrity of the assessment process, it may be necessary to invalidate the exam that has been held and require the APP to arrange a free resit for candidates at their convenience.

Following an investigation by WSET® Awards, it may be necessary to apply one of more of the following sanctions against an individual candidate or candidates.

Letter of warning;

The disallowing of an examination result;

The invalidation of a certificate and/or unit certificate and recall of certification already issued;

Refusal of entry to future WSET®

All decisions with regard to malpractice will be communicated in writing within 20 working days following receipt of supporting documentation.  Where it is not possible to respond within this timeframe, a written response will be given providing a date for completion.

Any candidate, educator, invigilator or APP has the right to appeal any decision made against them using the General Appeals section of this handbook, or as detailed in the WSET® Customer Service Statement .

Conflicts of Interest Policy


Equal Opportunities Policy


Complaints Policy


This APP is approved by WSET Awards which is subject to regulation by the UK Governments regulator, OfQual.  As a regulated awarding organisation, they are required to identify, monitor and manage all conflicts of interest which may have an adverse effect on the qualifications they offer and we must take all reasonable steps to mitigate such adverse effect where it exists.

This document offers guidance to all individuals engaged in activities undertaken on behalf of WSET Awards, (the awarding organisation of the Wine & Spirit Education Trust) which have potential to lead them to act contrary to the interests of WSET Awards in the development, delivery, assessment and award of its regulated qualifications.

It defines what is meant by conflict of interest, describes such conflict of interest in the context of working with WSET Awards, identifies those conflicts of interest that can be managed and are therefore acceptable and those that cannot be managed and are therefore unacceptable.  It also gives examples of potential conflict of interest.

Scope of this policy

This policy is applicable to all members of staff employed by the Wine & Spirit Education Trust in whatever capacity and to any individual acting on behalf of WSET Awards.  This includes those involved in the development of WSET qualifications, question setting, marking of assessments, delivery of WSET programs of study leading to WSET qualifications, marketing of WSET qualifications, production of study materials, examination papers, qualification certificates and all other associated resources and services.

It relates to WSET regulated qualifications offered  in the United Kingdom and  International markets.

Definition of conflict of interest

Conflict of interest exists where an individual has interests or loyalties that could adversely influence their judgement, objectivity or loyalty to WSET Awards when conducting activities associated with our qualifications.  These can arise in many different aspects of awarding organisation activity, such as:

An individual whose personal interests or loyalties conflict with their awarding organisation involvement

An individual who receives remuneration for services that conflict with their awarding organisation involvement

An individual whose acts put WSET Awards in a position of non-compliance with its regulatory responsibilities.

Whilst it would be impossible to give a definitive list of scenarios presenting potential for conflict of interest, the following have been identified resulting from WSET Awards Risk Management review as being of primary significance.  However, other scenarios will constitute conflict of interest, and we will take actions to redress any such instances that come to our attention other than by declaration from the individual concerned.  Such actions may also include the imposition of sanctions, if deemed appropriate.

Specific examples of conflict of interest include the following:

The undertaking of any assessment of candidates by an individual who has a personal interest in the result of the assessment for any or all individuals concerned.

The undertaking of any moderation of assessment of candidates by an individual who has a personal interest in the result of the assessment for any or all individuals concerned..

The tutoring of candidates by any individual involved in the assessment process.

The undertaking of a WSET regulated qualification by any individual employed by an APP.

The undertaking of a WSET regulated qualification by any individual employed by WSET Awards.

The invigilation of a WSET regulated qualification by any individual involved in the delivery of training leading to the assessment.

The delivery of any “coaching sessions” to examination candidates by any individual involved in the assessment of candidate scripts or the authoring of examination questions.

The employment by an APP of individuals engaged in the delivery of taught programs or in the role of Internal Assessor in another APP

Some of these examples can be managed and are therefore acceptable. For example, the marking of tasting assessments by Level 3 Internal Assessors is ALWAYS verified by WSET Awards as they clearly have an interest in the results of the assessments of learners they have taught and this constitutes a conflict of interest, and our verification process mitigates this possibility.  Similarly, where an employee of the WSET or one of its APPs undertakes a WSET qualification, we can put measures in place to maintain the integrity of the assessment, PROVIDED we are notified of this conflict of interest in advance of the assessment.  However, it would be totally inappropriate for any individual involved in the authoring of examination questions or the compilation of examination papers to teach or coach learners under any circumstances as there are no options for us to mitigate the effect of this clear conflict of interest.


Any individual engaged with WSET Awards in the provision of our regulated qualifications, as identified under the scope of this policy, is required to make a Declaration of Interest by informing WSET Awards of any potential conflict of interest.  Certain individuals, such as those involved in the assessment process are also required to submit a signed declaration of Non-disclosure.  It is essential that any conflict of interest is declared to WSET Awards immediately to ensure this does not compromise our status of compliance with our regulator, Ofqual. Any APP who fails to declare a potential conflict of interest is in breach of our criteria for approval, and sanctions may be applied to their approval status as a result of any such non-disclosure.

WSET Awards has processes and procedures in place to manage actual or perceived conflict of interest.  These include the exclusive involvement of WSET Awards staff in the creation of all assessment materials, moderation of all internal assessment conducted by the APP and moderation of all written examinations not marked by optical mark readers.  There are of course many other instances of conflict of interest for which we do not have documented procedures in place.  Such instances will be handled on an individual basis to ensure that the integrity of our assessments is not compromised.


The Director, WSET Awards and the Centre Co-ordinator and Quality Control Manager have responsibility for the day to day managing of conflicts of interest relating to functions of WSET Awards.  The members of the Senior Management Team of the Wine and Spirit Education Trust have responsibility for the day to day managing of conflicts of interest relating to functions of the Wine and Spirit Education Trusts functions as a whole.

It is the responsibility of all individuals engaged in the provision of WSET qualifications, in all and any capacity, to promptly report any potential for conflict of interest to the Centre Co-ordinator and Quality Control Manager at WSET Awards.

All instances of conflict of interest will be recorded in WSET Awards Incidents Register, including details of steps taken to mitigate any adverse effect resulting from such conflict of interest.  The Director, WSET Awards is responsible for determining what action needs to be taken to mitigate any adverse effect and for deciding when and how matters relating to actual or potential conflict of interest should be escalated within the Wine & Spirit Education Trust, to the Board of Trustees or to the Regulator, Ofqual.

This APP fully supports the principles of Equal Opportunities. We strive to ensure that all candidates for our qualifications are treated fairly and on an equal basis

Equal Opportunities are assured by:

the selection, recruitment and training of those working for this APP;

consideration at an early stage in the development of new schemes or qualifications;

ensuring that the format and content of all syllabi, examinations and other do not discriminate against anyone which is the responsibility of WSET Awards by whom we are approved to teach WSET qualifications;

ensuring there are no barriers to entry to units and qualifications, which we deliver and/or offer, for disabled people, women or men, or people from different racial groups, other than those directly related to the integrity of the units or qualifications.  The nature of any barriers will be stated and the inclusion of the requirements that create the barrier justified only and explicitly in terms of the integrity of the unit or the qualification.  Details of how the effect of any barriers will be mitigated will be recorded, including using access arrangements or including reasonable adjustments.

clarifying the responsibility of all members of staff and/or consultants, who are involved in the delivery of WSET courses within this APP, to comply with this policy.  In particular external parties invited by this APP to contribute to these development arrangements must also, as representatives of relevant learners, ensure that the views of learners and others are taken into account in the development of QCF units and qualifications.

anonymous assessment of examination candidates wherever possible;

promoting practices and procedures that give equal opportunities to everyone;

being required to have equal opportunity policies in place;

the variation of any conventional rules and regulations for the conduct of examinations which might inhibit the performance of candidates with specific needs, provided that the standard, quality and integrity of the assessment is not compromised.

working as appropriate with relevant organisations and agencies to develop measures to identify and prevent inequality of opportunity;

making every effort to ensure that there is equality of opportunity in its assessment process, regardless of the candidate’s gender, age, racial origin, religious persuasion, sexual orientation or disability;

ensuring, to the best of our ability, that any documentation produced does not contain language or images which may be regarded as offensive or stereotypical, and that they reflect the diversity of contemporary society;

This APP is an equal opportunities organisation and will consider applications from any organisation or individual who can demonstrate that they meet our approval criteria. This policy is published  on our website or Candidate Booking Form and will be provided to any student on demand


This APP  will comply with all current and relevant legislation and this policy will be monitored and reviewed annually.  At the time of writing relevant legislation includes, but is not limited to:

The Rehabilitation of Offenders Act 1974;

The Sex Discrimination Act 1975;

The NHS Community Care Act 1990;

The Disability Discrimination Act 1995;

The Asylum and Immigration Act 1996;

The Human Rights Act 1998;

The Sex Discrimination (Gender Realignment) Regulations 1999;

The Employment Equality (Religion or Belief) Regulation 2003;

The Employment Equality (Sexual Orientation) Regulation 2003;

The Equal Pay Act 1970 (Amendment) Regulations 2003;

The Race Relations Act 1976, The Race Relations (Amendment) Act 2000, and Amendment Regulations 2003;

The Gender Recognition Act 2004;

The Employment Equality (Sex Discrimination) Regulations 2005;

The Employment Equality (Age) Regulation 2006;

The Equality Act 2006; and

The Equality Act (Sexual Orientation) Regulation 2007.

Note, from April 2010 the Equality Bill may come into force, which will replace all existing discrimination legislation and the Acts listed above.

As part of the monitoring of candidates registering for a WSET® qualification we will collect information on diversity, requests for special consideration, access arrangements and feedback from learners, centers and other stakeholders.

All relevant issues identified as suggesting our provision or services have unnecessary impact on learners will be reported back to the Centre Registration and Quality Assurance Manager who will be responsible for leading on introducing amendments to provision and/or services where necessary and in accordance with our documented procedures for developing and reviewing units and qualifications.  Details of the outcomes of each review will be made available to the qualification regulators upon request.


Candidates who believe they have been discriminated against should contact us in the first instance for advice.


Complaints against any action or practice which threatens the integrity of our courses, either APP center staff or representative or student should in the first instance be discussed with APP center contact.  The APP undertakes to investigate all complaints in a thorough and professional manner.  This includes, but is not limited to:

Notifying the complainant that their complaint will be investigated by a named individual within a given timescale

Informing the complainant of the outcome of the investigation in writing

Informing the complainant of the appropriate escalation of the complaint if the initial outcome is still unsatisfactory.

An outline of the problem and the main points should be documented and dated.

If the problem is not resolved at this stage the candidate should contact a higher authority in WSET.

Examples of complaints would be

Dis-satisfaction with teaching, facilities or administration of WSET courses

Allegations of discrimination or unfair treatment

Falsifying results, assisting candidates with answers

Allowing unauthorized material into the exam room e.g. phones, notes etc

Allowing candidates to copy from each other.

Disruptive behaviors e.g. talking during the exam

Please contact us with your complaint. Phillip Patti: phillip@subvinocompany.com. Please let us know of your complaint within seven (7) business days so that we may address it promptly. We will respond within three (3) business days to address the issue.

Complaints against the awarding body

Complaints against the Wine and Spirit Education Trust should, in the first instance, be discussed with the center contact as above and documented evidence will then be forwarded to The Wine and Spirit Education Trust who have their own complaints policy.

Candidates who are unhappy with their exam results can appeal via the center contact.

The Wine and Spirit Education Trust will investigate the charges are on the website:



Data Policy


Last Updated March 22, 2019


1. Data protection principles

Subvino is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

  • processed lawfully, fairly and in a transparent manner in relation to individuals;

  • 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;

  • adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

  • accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

  • kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are 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 organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

  • 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 organizational measures.”

2. General provisions

This policy applies to all personal data processed by Subvino.

The Responsible Person shall take responsibility for Subvino’s ongoing compliance with this policy.

This policy shall be reviewed at least annually.

3. Lawful, fair and transparent processing

To ensure its processing of data is lawful, fair and transparent, Subvino shall maintain a Register of Systems.

The Register of Systems shall be reviewed at least annually.

Individuals have the right to access their personal data and any such requests made to Subvino shall be dealt with in a timely manner.

4. Lawful purposes

All data processed by Subvino must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).

Subvino shall note the appropriate lawful basis in the Register of Systems.

Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Subvino’s systems.

5. Data minimisation

Subvino shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

6. Accuracy

Subvino shall take reasonable steps to ensure personal data is accurate.

Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / removal

To ensure that personal data is kept for no longer than necessary, Subvino shall put in place an archiving policy for each area in which personal data is processed and review this process annually.

The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security

Subvino shall ensure that personal data is stored securely using modern software that is kept-up-to-date.

Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.

When personal data is deleted this should be done safely such that the data is irrecoverable.

Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Subvino shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).


These Policies will be available online, and updated regularly, at: