Global Data Protection & Compliance Disclosure

Effective Date: 1 October 2025

Last Updated: 1 October 2025

1. Introduction

Westcourt Advisory ("Westcourt", "we", "our", or "us") operates as a global strategic advisory firm providing intelligence, structuring, and jurisdictional consulting services to international clients. We recognize the diversity of data protection laws across jurisdictions and commit to maintaining the highest global standards of data privacy, security, and ethical governance.

This Disclosure outlines Westcourt's adherence to data protection frameworks across all operating jurisdictions, including but not limited to the European Union (GDPR), United Kingdom (UK DPA 2018), Australia (Privacy Act 1988), and the United States (state-level privacy laws including CCPA, CPRA, and others).

2. Foundational Principles

Across all jurisdictions, Westcourt adheres to the following universal data protection principles:

Lawfulness, fairness, and transparency
Purpose limitation
Data minimization
Accuracy
Storage limitation
Integrity and confidentiality
Accountability

3. Global Compliance Framework

Westcourt's compliance model integrates region-specific requirements under a unified data governance policy.

A. Europe (GDPR & UK DPA 2018)

Westcourt acts as a Data Controller.
Lawful bases include consent, contract, and legitimate interest.
Transfers governed by Standard Contractual Clauses (SCCs).

B. Australia (Privacy Act 1988 & APPs)

Compliance with Australian Privacy Principles (APPs).
Sensitive data handled with elevated security.

C. United States (CCPA/CPRA and State Acts)

Clients may opt out of personal data sales.
Disclosure of data categories collected and shared.
Non-discrimination for rights exercised.

D. Asia-Pacific

Compliance with Singapore's PDPA, Hong Kong's PDPO, and other regional frameworks.
Cross-border transfer protocols in accordance with local law.

E. Middle East & Africa

Adherence to UAE's data laws and South Africa's POPIA.
Engagement with evolving regional standards.

4. Data Transfers and International Operations

Given Westcourt's global client base, data may be transferred across jurisdictions. All transfers are protected by encryption, access controls, and binding corporate rules (BCRs) or SCCs.

5. Data Subject Rights (Universal)

Regardless of jurisdiction, clients may:

Request confirmation of data being processed
Request a copy of their personal data
Request correction or deletion
Object to processing or withdraw consent
Request data portability

Requests: privacy@westcourtadvisory.com

6. Data Breach and Incident Management

In the event of a breach, Westcourt will:

Assess scope and impact
Notify affected parties and regulators
Implement corrective measures
Maintain a breach log

7. Data Retention and Deletion

Client data is retained only for the duration of engagement or legal necessity. Upon completion, data is securely deleted or anonymized. Retention policies are reviewed annually.

8. Security Framework

Westcourt employs:

AES-256 encryption
TLS 1.3 communications
Multi-factor authentication
Segregated international servers
Ongoing penetration testing

9. Data Protection Governance

A Data Protection Officer (DPO) oversees compliance, audits, and breach management.

Contact: privacy@westcourtadvisory.com

10. Updates

This Disclosure is reviewed annually and updated to reflect evolving legal requirements. Revisions will be posted at https://westcourtadvisory.com.

11. Legal Notice

Westcourt Advisory provides strategic intelligence and jurisdictional structuring services only. We do not offer legal, accounting, or investment services or manage client funds. All personal data handled by Westcourt is processed in accordance with applicable laws and professional confidentiality standards.