For the purpose of the EU General Data Protection Regulation (GDPR) (the Act), the data controller is English Salvage Ltd of North Road, Leominster, Herefordshire, UK, HR6 0AB
We may collect and process the following data about you:
Information you give us. You may give us information about you by filling in forms on our site http://www.englishsalvage.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site or by telephone, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, contact us with a view to sell us products and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, the sector you work in or are interested in, financial and credit card information, personal description and photographs.
Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
We use information held about you in the following ways:
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
We may disclose your personal information to third parties:
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted [using SSL technology]. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.
English Salvage Ltd ("We") are committed to protecting and respecting your privacy.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller - A controller determines the purposes and means of processing personal data.
Data processor - A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing - means 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.
Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
English Salvage Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: English Salvage Ltd, north Road, Leominster, Herefordshire, HR6 0AB. For all data matters contact Pru Woods at English Salvage Ltd, north Road, Leominster, Herefordshire, HR6 0AB.
We use your personal data for the following purposes:
We process personal information to enable us to buy, sell, promote and advertise our products and services; maintain our own accounts and records; support and manage our employees; the trading and sharing of personal information; to inform individuals of news, events or activities; the use of CCTV systems for crime prevention.
Description of processing:
The following is a broad description of the way this organisation/data controller processes personal information. To understand how your own personal information is processed you may need to refer to any personal communications you have received, check any privacy notices the organisation has provided or contact the organisation to ask about your personal circumstances.
You may give us information about you by filling in forms on our site www.englishsalvage.co.uk or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site,[enter a competition, promotion or survey, and when you report a problem with our site.
With reference to the categories of personal data described in the definitions section, we may process the following categories of your data:
We have obtained your personal data from you contacting us either through our website, or by email or telephone when you have contacted us with a view to you buying from us, or selling to us. We may obtain your personal data when you engage with us on our social media sites. In the case of potential suppliers we may find your details online and contact you.
Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data may be one or more of the following:
Consent of the data subject;
You have actively consented with a positive opt-in. We maintain a record of your consent.
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
Processing necessary for compliance with a legal obligation
- An employer needs to process personal data to comply with its legal obligation to disclose employee salary details to HMRC. The employer can point to the HMRC website where the requirements are set out to demonstrate this obligation. In this situation it is not necessary to cite each specific piece of legislation.
- A court order may require you to process personal data for a particular purpose and this also qualifies as a legal obligation.
- For instance the company has a legal requirement to record and notify HMRC of all sales under the EC Sales list.
Processing necessary to protect the vital interests of a data subject or another person
An individual is admitted to the A & E department of a hospital with life-threatening injuries following a serious accident at work. The disclosure to the hospital of the individual’s medical history is necessary in order to protect his/her vital interests.
Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject
- We have a legitimate interest in marketing our goods to existing customers to increase sales’.
The GDPR does not have an exhaustive list of what purposes are likely to constitute a legitimate interest. However, the recitals do say the following purposes constitute a legitimate interest:
Therefore, if you are processing for one of these purposes you may have less work to do to show that the legitimate interests basis applies.
The recitals also say that the following activities may indicate a legitimate interest:
Special categories of personal data (article 9 of GDPR)
Our lawful basis for processing your special categories of data:
Your personal data will be treated as strictly confidential, and will be shared only with appropriate recipients, required to fulfil our contract with you or our legal responsibilities, for example delivery companies; or HMRC for taxation purposes.
We keep your personal data for no longer than reasonably necessary, such as for a period of 7 years in order to fulfil any legal duties for financial or legal record keeping. Examples include: in case of any legal claims/complaints; for safeguarding purposes etc.
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so may have the following consequences: we may be unable to fulfil our contract with you (for example, if you do not provide your address we may not be able to arrange a collection or a delivery to you.)
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
We do not transfer personal data outside the eea.
WE DO NOT USE ANY FORM OF AUTOMATED DECISION MAKING IN OUR BUSINESS.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
To exercise all relevant rights, queries or complaints please in the first instance contact Pru Woods, English Salvage Ltd, North Road, Leominster, Herefordshire, HR6 0AB.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
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English Salvage Ltd (The Company) uses closed circuit television (CCTV) images to provide a safe and secure environment for employees and for visitors to the Company’s business premises, such as clients, customers, contractors and suppliers, and to protect the Company’s property.
This policy sets out the use and management of the CCTV equipment and images in compliance with the EU General Data Protection Regulation (GDPR) and the CCTV Code of Practice.
The Company’s CCTV facility records images only. There is no audio recording i.e. conversations are not recorded on CCTV (but see the section on covert recording).
The purposes of the Company installing and using CCTV systems include:
Cameras are located at strategic points throughout the Company’s business premises, principally at the entrance and exit points. The Company has positioned the cameras so that they only cover communal or public areas on the Company’s business premises and they have been sited so that they provide clear images. No camera focuses, or will focus, on toilets, shower facilities, changing rooms, staff kitchen areas, staff break rooms or private offices.
All cameras (with the exception of any that may be temporarily set up for covert recording) are also clearly visible.
Appropriate signs are prominently displayed so that employees, clients, customers and other visitors are aware they are entering an area covered by CCTV.
Images produced by the CCTV equipment are intended to be as clear as possible so that they are effective for the purposes set out above. Maintenance checks of the equipment are undertaken on a regular basis to ensure it is working properly and that the media is producing high quality images.
Images may be recorded either in constant real-time (24 hours a day throughout the year), or only at certain times, as the needs of the business dictate.
As the recording system records digital images, any CCTV images that are held on the hard drive of a PC or server are deleted and overwritten on a recycling basis and, in any event, are not held for more than [one month) Once a hard drive has reached the end of its use, it will be erased prior to disposal.
Images that are stored on, or transferred on to, removable media such as CDs are erased or destroyed once the purpose of the recording is no longer relevant. In normal circumstances, this will be a period of (one month). However, where a law enforcement agency is investigating a crime, images may need to be retained for a longer period.
Access to, and disclosure of, images recorded on CCTV is restricted. This ensures that the rights of individuals are retained. Images can only be disclosed in accordance with the purposes for which they were originally collected.
The images that are filmed are recorded centrally and held in a secure location. Access to recorded images is restricted to the operators of the CCTV system and to those line managers who are authorised to view them in accordance with the purposes of the system. Viewing of recorded images will take place in a restricted area to which other employees will not have access when viewing is occurring. If media on which images are recorded are removed for viewing purposes, this will be documented.
Disclosure of images to other third parties will only be made in accordance with the purposes for which the system is used and will be limited to:
The Managing Director of the Company (or another senior director acting in their absence) is the only person who is permitted to authorise disclosure of images to external third parties such as law enforcement agencies.
All requests for disclosure and access to images will be documented, including the date of the disclosure, to whom the images have been provided and the reasons why they are required. If disclosure is denied, the reason will be recorded.
Under the EU General Data Protection Regulation (GDPR), individuals have the right on request to receive a copy of the personal data that the Company holds about them, including CCTV images if they are recognisable from the image.
If you wish to access any CCTV images relating to you, you must make a written request to the Company’s Data Protection Officer. Your request must include the date and approximate time when the images were recorded and the location of the particular CCTV camera, so that the images can be easily located and your identity can be established as the person in the images. The Company will respond promptly and in any case within 40 calendar days of receiving the request.
The Company will always check the identity of the employee making the request before processing it.
The Data Protection Officer will first determine whether disclosure of your images will reveal third party information as you have no right to access CCTV images relating to other people. In this case, the images of third parties may need to be obscured if it would otherwise involve an unfair intrusion into their privacy.
If the Company is unable to comply with your request because access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders, you will be advised accordingly.
The Company will only undertake covert recording with the written authorisation of the Managing Director (or another senior director acting in their absence) where there is good cause to suspect that criminal activity or equivalent malpractice is taking, or is about to take, place and informing the individuals concerned that the recording is taking place would seriously prejudice its prevention or detection.
Covert monitoring may include both video and audio recording.
Covert monitoring will only take place for a limited and reasonable amount of time consistent with the objective of assisting in the prevention and detection of particular suspected criminal activity or equivalent malpractice. Once the specific investigation has been completed, covert monitoring will cease.
Information obtained through covert monitoring will only be used for the prevention or detection of criminal activity or equivalent malpractice. All other information collected in the course of covert monitoring will be deleted or destroyed unless it reveals information which the Company cannot reasonably be expected to ignore.
The Company will ensure that all employees handling CCTV images or recordings are trained in the operation and administration of the CCTV system and on the impact of the EU General Data Protection Regulation (GDPR) with regard to that system.
Pru Woods is responsible for the implementation of and compliance with this policy and the operation of the CCTV system and they will conduct a regular review of the Company’s use of CCTV. Any complaints or enquiries about the operation of the Company’s CCTV system should be addressed to them.
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