When we process your personal data we are required to comply with the Data Protection Act 1998 (“DPA”) until 25 May 2018, and in substitution from 25 May 2018, the General Data Protection Regulation 2016 (“GDPR”) (the DPA and GDPR are together referred to as the “Data Protection Legislation”).
Your personal data includes all the information we hold that identifies you or is about you, including but not limited to your name, email address, postal address, phone number, date of birth, and in some cases opinions that we document about you.
Everything we do with your personal data counts as processing it, including collecting, storing, amending, transferring and deleting it. We are therefore required to comply with the Data Protection Legislation to make sure that your information is properly protected and used appropriately.
This fair processing notice provides information about the personal data we process about you, why we process it and how we process it.
“Harrison Spinks” is the data controller of the personal data you provide. Our Group Finance Director will have day to day responsibility for ensuring we comply with the Data Protection Legislation and dealing with any requests we receive from individuals exercising their rights under the Data Protection Legislation.
We process your personal data in order to fulfil the contract we have entered into with you, to receive services or goods from you, and/or to provide the services you have requested from us. We may also process your personal data to respond to any queries or comments you submit to us, including via our website.
We may need personal data from you to be able to enter into a contract with you and provide you with all the information you need. If we do not receive that personal data from you, we may be unable to fulfil our obligations to you.
We process most of your information on the grounds of our legitimate interests (i.e.processing that is necessary to continue our relationship with you and to provide you with or receive from you (as applicable) services or products), fulfilment of our contract with you or to comply with a legal obligation.
If none of the grounds set out above applies, we will obtain separate consent from you to the processing of your personal data. You can withdraw your consent at any time. This won’t affect the lawfulness of any processing we carried out prior to you withdrawing your consent.
We only transfer your personal data to the extent we need to. Recipients of your personal data include:
If we send marketing communications to you we will continue to do so for a 10 year period unless you unsubscribe or opt out. We do so on the grounds that many customers require new products within a 10 year period and so we feel it is in our legitimate interests to continue sending you information. In respect of all other personal data we hold about you, we will retain the data for 8 years following our last contact with you as our customer, supplier or contact. We retain your information for this period in case any issues arise or in case you have any queries. Your information will be kept securely at all times. Following the end of the 8 period, your files and personal data we hold about you will be permanently deleted or destroyed. If we are required to obtain your consent to send you marketing communications, any information we use for this purpose will be kept until you withdraw your consent, unless we have other legitimate reasons to retain the data. We will retain your personal data on a suppression list to ensure we don’t send you any more marketing communications if you unsubscribe or opt out.
You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/). These rights apply for the period in which we process your data.
1. Access to your data
You have the right to ask us to confirm that we process your personal data, as well as access to / copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this fair processing notice.
We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.
We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we’ll let you know.
2. Rectification of your data
If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.
3. Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.
4. Right to restrict processing
In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you
5. Data portability
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:
We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.
6. Right to object
You are entitled to object to us processing your personal data:
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
Automated decision making means making a decision solely by automated means without any human involvement. This would include, for example, an online credit reference check that makes a decision based on information you input without any human involvement. It would also include the use of an automated clocking-in system that automatically issues a warning if a person is late a certain number of times (without any input from HR, for example).
If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website - https://ico.org.uk/concerns/.
If you have any questions or would like more information about the ways in which we process your data, please contact our Group Finance Director.