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Glenlake International Ltd

General Privacy Notice

Introduction

Glenlake International Ltd is a controller of the information that we collect about you (‘personal data’).

This notice informs you how we use personal data and how we protect your privacy.

We abide by current UK law including the EU General Data Protection Regulations 2018 (GDPR).

The UK regulator is the information Commissioner’s Office and our licence number is: ZA427285

Data Protection Principles

Our company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

We will comply with data protection law and principleswhich means that your data will be:

• Used lawfully, fairly and in a transparent way.

• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

• Relevant to the purposes we have told you about and limited only to those purposes.

• Accurate and kept up to date.

• Kept only as long as necessary for the purposes we have told you about.

• Kept securely.

Scope

This policy applies to our processing of personal data for individuals other than:

• Glenlake employees, who should refer to the Employee Privacy Notice in the company’s employee handbook; and

• Applicants to vacancies with Glenlake who should refer to the Candidate Privacy Notice on our website.

We have a separate Website Privacy Policy and Cookie Policy.

The information we may collect, use and hold about you

We process your data in order to provide our products and services. In the course of business we may collect the following personal information when you provide it to us:

• Identity Data, such as your name, title, date of birth, job title and your employer,

• Contact Data, such as your home and work addresses, personal and work email addresses and personal and work telephone numbers,

• Third Party Data, namely Identity Data, Contact Data and Document Data relating to your business colleagues and other contacts,

• Financial Data, such as bank account, and payment card details,

• Transaction Data, including details about payments to and from you, and other details of products and services you purchase from us,

• Technical Data, including IP addresses, your log-in data, browser type and version, timezone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website,

• Usage Data, including information about how you use our website, products and services, and

• CCTV images of you may be captured on our premises.

We use your personal information primarily to enable us to provide you with our products in accordance with your instructions. The information will be held in hardcopy and electronic format.

You are responsible for ensuring the accuracy of all the personal data you supply to us and we will not be held liable for any errors unless you have advised us previously of any changes in your personal data.

 

Other sources of data and who we share your data with

Depending on the nature of the service we provide, the lawful basis and purpose of processing, we may need to share your personal data with other parties (examples listed below). These parties are subject to data protection legislation and principles. We will usually have notified you of the sharing of your data with these parties. However, certain legislation may prevent us from doing so. Many of these parties both receive personal data from us and provide it to us:

• Our distribution partners who may deliver goods to you, details off which can be provided upon request,

• HM Revenue & Customs, the Information Commissioner’s Office and any other regulators and other authorities who require reporting of processing activities in certain circumstances,

• credit-reference agencies,

• professional advisers and business networks with which we are connected,

• our outsourced IT services provider, together with providers of wi-fi, IT and system administration services to our business, and other online cloud and data-room providers,

• our professional advisers (including solicitors, barristers, bankers, auditors and insurers),

• our quality assurance assessors,

• business partners, suppliers and sub-contractors to the extent we consider it reasonably necessary for us to perform our services,

• analytics and search engine providers that assist us in the improvement and optimisation of our website, and

• third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this policy.

• We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

We may also obtain information from publicly-available databases, such as Companies House or details on a company website.

Furthermore, we will disclose your personal information:

• in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;

• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about customers will be one of the transferred assets;

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of our company, our clients, or any other third parties.

The company will not transfer your data outside the European Economic Area.

If you fail to provide personal information.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may stop providing that service but we will notify you if this is the case at the time.
 

Data Security

The company takes the security of your data seriously and has internal policies and controls in place to ensure that your data is not lost accidentally destroyed, misused or disclosed and is not accessed except by our employees in the proper performance of their duties. We limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have a range of security measures concerning access to our premises and systems. We have put in place procedures to deal with any suspected security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Reasons we can legally collect and use your personal information.

We may use your personal information for a number of different purposes and for each purpose we must have a lawful basis for processing your personal data. We may rely on the following lawful bases to collect and use your personal or sensitive personal data:

Consent: where you have given clear consent for us to process your personal data for a specific purpose.

Contract: where the processing is necessary for a contract you have with us.

Legal obligation: where the processing is necessary for us to comply with the law (not including contractual obligations).

Vital interests: where the processing is necessary to protect someone’s life.

Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.

Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.

How long does the company keep data?

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

Your rights

As a data subject, under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a 'data subject access request'). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

• Object to processing of your personal information where we are relying on a legitimate interest) or those of the third party and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

• Request the transfer of your personal information to another party.

If you wish to review, verify, correct or request erasure of your personal information, object to the processing of your personal data or request that we transfer a copy of your personal information to another party, please contact the Data Security Manager in writing.

Data Security Manager, Paul Salmon, Glenlake International Ltd, F7 Fellows Court, Anchor Brook Industrial Park, Aldridge, West Midlands WS9 8BZ or email info@glenlake-int.co.uk

If you believe that the company has not complied with your data protection rights, you can complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

The ICO’s contact details are as follows:

 

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone – 0303 123 1113 (local rate) or 01625 545 745

Website – https://ico.org.uk/concerns

Last amended 12th June 2018