We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business. We will ensure that we treat personal information lawfully and correctly.
We may have to collect and use information about people with whom we work. This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.
To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).
This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our business function as described below. It also covers our response to any data breach and other rights under the GDPR.
This policy applies to the personal data of job applicants, existing and former employees, apprentices, volunteers, placement students, contractors, suppliers, customers and third parties. These are referred to in this policy as relevant individuals.
We only collect personal information about you where it is completely necessary or you have consented, and we ensure that we only collect information that we need and only hold it for as long as deemed necessary.
We will not sell your personal information to third parties
We use third-party suppliers to help us provide an excellent service to you and our staff. Where we share personal information with these suppliers, we have the appropriate contracts or controls in place, which will assess the security of their processing arrangements.
We will protect your personal information with an appropriate combination of technical and organisational measures.
You have rights to your information. Please see policy of your rights in relation to your data.
We retain your data only for as long as is necessary.
If you have a complaint, please see how to contact us on at the end of the policy.
If you have any questions about how we process your information, please see how to contact us at the bottom of the policy
“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier or email. It can also include pseudonymised data.
“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).
“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.
“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
C) 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 will be fair, lawful and transparent
b) data be collected for specific, explicit, and legitimate purposes
c) data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
d) data will be 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 will be 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 will comply with the relevant GDPR procedures for international transferring of personal data
D) TYPES OF DATA HELD
We keep several categories of personal data in order to carry out effective and efficient processes. We keep this data in a personnel file and we also hold the data within our computer systems.
Specifically, we hold the following types of data:
a) Supplier contact details for BRC, food safety, ordering and contracts
b) Customer contact details for BRC, food safety, daily business working, contracts and supply of goods
c) HR for staff job applicants and pay
d) Prospective customers for marketing
e) Supply of services
All of the above information is required for our business activities.
E) YOUR RIGHTS
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. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
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.
More information can be found on each of these rights in our separate policy.
In order to protect the data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection.
We have also appointed employees with responsibility for reviewing and auditing our data protection systems.
G) LAWFUL BASES OF PROCESSING
We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.
Where no other lawful basis applies, we may seek to rely on obtaining your consent in order to process data.
However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. You will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.
H) ACCESS TO DATA
As stated above, you have a right to access the data that we hold. To exercise this right, you should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.
No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.
Further information on making a subject access request is contained in our Subject Access Request policy.
I) DATA DISCLOSURES
The Company may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:
a) any benefits operated by third parties;
b) to comply with health and safety, occupational health obligations, food safety issues, BRC, FSA,TS and product traceability
c) HR management and administration
d) the smooth operation of any insurance policies or pension plans;
e) to assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders or to assess or collect any tax or duty.
These kinds of disclosures will only be made when strictly necessary for the purpose.
J) DATA SECURITY
We are aware that hard copy personal information should be kept in a locked filing cabinet, drawer, or safe.
All employees are aware of their roles and responsibilities when their role involves the processing of data. All employees are instructed to store files or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops etc when unattended. No files or written information of a confidential nature are to be left where they can be read by unauthorised people.
Where data is computerised, it is coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up.
K) THIRD PARTY PROCESSING
Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.
L) INTERNATIONAL DATA TRANSFERS
The Company does not transfer personal data to any recipients outside of the EEA.
M) REQUIREMENT TO NOTIFY BREACHES
All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.
More information on breach notification is available in our Breach Notification policy.
New employees are required to read and understand the policies on data protection as part of their induction.
All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.
The nominated protection officers for the Company are trained appropriately in their roles under the GDPR.
All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.
The Company keeps records of its processing activities including the purpose for the processing and retention periods in its HR Data Record. These records will be kept up to date so that they reflect current processing activities.
P) DATA PROTECTION COMPLIANCE
Our appointed compliance officers in respect of our data protection activities are:
Julie Painting & Haydee Scarsbrook
Four Anjels Ltd.
Unit 10, Furlong Park, Bishops Cleve Business Park. Cheltenham, GL52 8TW | Tel: 01242 383327