In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our customers and suppliers, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
This notice applies to current and former clients and suppliers
A. DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
a. processing is fair, lawful and transparent
b. data is collected for specific, explicit, and legitimate purposes
c. data collected is adequate, relevant and limited to what is necessary for the purposes of processing
d. data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
e. data is not kept for longer than is necessary for its given purpose
f. data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
g. we comply with the relevant GDPR procedures for international transferring of personal data
B. TYPES OF DATA HELD
We keep several categories of data on our customers and suppliers in order to carry out effective and efficient processes. We keep this data within our computer systems and files.
Specifically, we hold the following types of data:
a. Name and address
c. Email address
d. Bank details (suppliers only)
e. Transaction data
f. Insurance and certification details (suppliers only
g. VAT registration number
C. COLLECTING YOUR DATA
You provide several pieces of data to us directly during the procurement process.
D. LAWFUL BASIS FOR PROCESSING
The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the contract we have with you.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
|Activity requiring your data||Lawful basis|
|Invoicing||Our legitimate interests|
|Payments||Our legitimate interests|
|VAT return||Legal Obligations|
|Class Booking||Completion of contract|
|Collect and recover money owed to us||Our legitimate interests|
E. SPECIAL CATEGORIES OF DATA
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
F. FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment, or administer contractual benefits.
G. CRIMINAL CONVICTION DATA
We do not collect any information about criminal convictions and offences.
H. WHO WE SHARE YOUR DATA WITH
Employees within our company who have responsibility for carrying administrative procedures will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR.
We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We do not share your data with bodies outside of the European Economic Area.
I. OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transactions.
J. PROTECTING YOUR DATA
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
K. RETENTION PERIODS
We only keep your data for as long as we need it for, which will be at least for the minimum of 7 years to comply with the correct legislation as set out by HMRC.
You have the following rights in relation to the personal data we hold on you:
a. the right to be informed about the data we hold on you and what we do with it;
b. the right of access to the data we hold on you.
c. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
d. the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
e. the right to restrict the processing of the data;
f. the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
g. the right to object to the inclusion of any information;
h. the right to regulate any automated decision-making and profiling of personal data.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
N. MAKING A COMPLAINT
If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
O. DATA PROTECTION COMPLIANCE
Our appointed compliance officer in respect of our data protection activities is: