LBN GROWTH APP
Government Data Requests & Meta Data Protection Policy
Version: 1.0
Date: 14 October 2026
Policy Owner: LBN Management
Applies to: LBN Growth App, its authorised administrators, employees, contractors, and service providers.
1. Purpose
This policy establishes how London Business Network (LBN) handles government, law-enforcement, national-security, and other legally binding requests for personal data processed through the LBN Growth App.
It specifically covers personal data obtained through Meta platforms, including WhatsApp Business integrations.
LBN is committed to protecting personal information, complying with applicable laws, and preventing unauthorised or excessive disclosure.
2. Scope
This policy applies to:
• Personal information received through Meta APIs and WhatsApp Business.
• Customer and business contact information.
• Messages, communications, and associated metadata.
• Information stored within the Growth App, including its communications and CRM systems.
• Government and law-enforcement requests seeking access to such information.
3. Government and National-Security Requests
LBN will disclose personal information to government authorities only where legally required or otherwise lawfully permitted following appropriate review.
All requests must be referred to LBN Management before any information is disclosed.
No employee, contractor, or automated system may independently authorise disclosure.
4. Legal Review Procedure
Upon receiving a government request, LBN will:
1 Verify authenticity: Establish the identity and authority of the requesting organisation.
2 Assess legal validity: Examine the legal basis, jurisdiction, scope, and enforceability of the request.
3 Seek legal advice: Obtain qualified legal advice where necessary.
4 Determine necessity: Establish whether disclosure is legally required and proportionate.
5 Authorise disclosure: Require management approval before releasing information.
Requests that cannot be authenticated or legally justified will not be fulfilled.
5. Challenging Unlawful Requests
LBN will assess whether requests are unlawful, excessively broad, disproportionate, or otherwise legally defective.
Where appropriate, LBN will:
• Seek clarification or modification.
• Request that the scope be narrowed.
• Challenge the request through available legal procedures.
• Seek judicial review or other appropriate remedies where justified.
LBN will not voluntarily disclose personal information in response to requests determined to be unlawful.
6. Data Minimisation
Where disclosure is legally required, LBN will:
• Provide only information necessary to satisfy the valid request.
• Limit disclosure to the relevant individuals, records, and time periods.
• Exclude unrelated personal information.
• Use appropriate secure transmission methods.
• Avoid disclosing entire datasets where narrower disclosure is sufficient.
The governing principle is minimum necessary disclosure.
7. Request and Disclosure Register
LBN will maintain a confidential register documenting government requests.
Each entry must record:
| Field | Required information |
|---|---|
| Request ID | Unique reference |
| Date received | Date of request |
| Requesting authority | Organisation and jurisdiction |
| Legal basis | Relevant legal authority |
| Information requested | Description and scope |
| Legal assessment | Findings and advice |
| Decision | Approved, rejected, challenged, or pending |
| Data disclosed | Description of any information released |
| Authorisation | Approving person |
| Date completed | Date of final response |
The register must be restricted to authorised personnel and retained according to applicable legal and data-retention requirements.
8. Confidentiality and Security
All requests and associated records must be handled confidentially.
Access will be restricted to personnel responsible for legal assessment, compliance, and authorised disclosure.
LBN will implement appropriate technical and organisational measures to protect the information against unauthorised access, alteration, or disclosure.
9. Personal Data Protection
LBN will process Meta-derived personal data in accordance with applicable data-protection legislation, including the UK GDPR and Data Protection Act 2018, where applicable.
Government requests do not automatically override data-protection obligations.
Any disclosure must have an appropriate lawful basis.
10. Accountability
LBN Management is responsible for:
• Implementing and maintaining this policy.
• Reviewing government requests.
• Authorising legally permissible disclosures.
• Ensuring appropriate records are maintained.
• Reviewing the policy annually or following material regulatory changes.
11. Policy Adoption
This policy becomes effective upon formal approval by LBN Management.
It does not retrospectively establish procedures or compliance practices that did not previously exist.
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META DATA-HANDLING DECLARATION
Following adoption and operational implementation, LBN can describe its procedures as follows:
Legal Review: Government requests are subject to management review, verification of legal authority, and legal advice where necessary.
Challenging Requests: LBN maintains a procedure for challenging unlawful, disproportionate, or excessively broad requests.
Data Minimisation: Disclosures are restricted to the minimum personal information legally necessary.
Documentation: Government requests, assessments, decisions, and disclosures are recorded in a confidential register.
Historical Disclosures: The number of disclosures made during the preceding 12 months must be established separately from the adoption of this policy.