GENERAL DATA PROTECTION REGULATION 2018 – PRIVACY POLICY STATEMENT
At J. A. Coles (Removal Contractors) Limited we do all we can to respect client, employee and supplier (all herein referred to as “person”) rights to privacy and to protect personal information.
How we use, and secure personal information
We use and process various types of personal information, including basic information eg. name, address and contact details; bank and payment details; training, licence, passport and customs details. All of the personal information used will have been provided willingly by a person, or created by them through use of our products and services eg. our website quote request option. We also collect information from third party organisations a person deploys, such as internet removal quotation organisations we subscribe to.
We are committed to ensuring that personal information is secure with us and with third parties who may act on our behalf eg. shipping suppliers. We use many tools eg. encryption technology to make sure that personal information remains confidential and accurate and we may monitor or record calls, emails, text messages or other communications in order to protect a person and us too.
Transferring information overseas
Most of the information we hold for a person will be used and stored in the UK. However, we may transfer information overseas as some of our operations and third party providers eg. agents are not based in the UK. We will make sure that any transfer to another country is legal and that personal information is always kept safe.
Communications about personal records
We use a person’s contact details provided willingly to us to send that person information relevant to their context within the operation of our business, provision of services the person may have procured, and maintenance of their account and or records: methods including by email, text, phone, fax and letter.
How long we keep personal information
We do not keep personal information for longer than we need to, which is usually in so far as the conclusion of the contract period, unless we are requested to keep it longer by a person or by legislative requirements eg. HMRC and DVSA archive periods.
Marketing
We will not send a person any marketing information relating to products and services unless they request us to do so, and we will not share personal information with third parties for their own marketing purposes.
A person’s rights
A person has a number of legal rights to control what we do with their personal information. For example, a person can ask us what information we have about them and request a copy of it; correct or update information that is wrong; stop us using their information in certain circumstances. Please note that in some cases, by asking us to do the latter it may mean that we are no longer able to provide a person with contracts or services. We actively review our policies and are open to resolve any complaints, but further guidance can be obtained by contacting the Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow SK9 5AF Tel: 0303 123 1113 or 01625 545 745 www.ico.org.uk
For further information please contact us or refer to our privacy policy document at www.colesremovals.co.uk
GENERAL DATA PROTECTION REGULATION 2018 (GDPR) PRIVACY POLICY
CONTENTS
1 Who we are
2 The information we process
3 How we obtain information
4 How we use and share information with suppliers
5 Sharing with third parties
6 Transferring information overseas
7 Marketing information
8 Communications about personal records
9 False information
10 How long we keep information
11 Security
12 A person’s freedom and rights
1 Who we are
1.1. This policy applies to all personal information processing activities carried out by J. A. Coles (Removal Contractors) Limited.
1.2. This policy incorporates our sister company D. J. Jeakins (Transport) Limited, thus herein similarly implied by referral to J. A. Coles (Removal Contractors) Limited.
1.3. J. A. Coles (Removal Contractors) Limited is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide). Within this policy, references to “we”, “us” or “our” are references to J. A. Coles (Removal Contractors) Limited.
1.4. Our principal address is 15 Tottenham Lane, London N8 9DJ and our contact details are:
• Telephone: 0208 808 9151
• Fax: 0208 808 2849
• Email: [email protected]
1.5. More information about J. A. Coles (Removal Contractors) Limited can be found at www.colesremovals.co.uk
1.6. At J. A. Coles (Removal Contractors) Limited we do all we can to respect and safeguard client and employee (plus suppliers – all herein referred to as “person”) rights to privacy and the protection of their personal information. The purpose of this policy is to explain how we collect and use personal information in connection with our business. “Personal information” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information).
2 The information we process
2.1 We will only collect and process personal information we have obtained with a person’s explicit consent at the start of, and for the duration of, that person’s relationship with us. We will limit the collection and processing of information, to information that is only necessary to achieve one or more legitimate interests as identified in this policy.
Personal information may include:
• basic personal information, including name and address, date of birth and contact details;
• financial information, appertaining to account settlement;
• goods and services provided;
• visual images and personal appearance (such as copies of passports);
• online profile information and activity, based on interaction with us and our websites.
Additional and relevant to employees only:
• information about family, (such as dependents, marital status, next of kin and contact details);
• education and employment information;
• visual images and personal appearance (such as copies of licences or security CCTV images);
• trade union membership;
• physical or psychological health details or medical conditions;
• where permitted by law, background checks.
2.2 GDPR defines a person under the age of sixteen years to be a child, thus, if the circumstances arise, we would not process any personal information without prior and explicit parental or custodial consent.
3 How we obtain information
3.1 Personal information comprises of all the information we collect and hold about a person and may
include:
• information freely given to us (client eg. quotation requests, employee eg. applications);
• information that we receive from third parties on a person’s behalf (client eg. removal import documentation, employee eg. reference requests);
• information that we learn about a person through our relationship with them (client eg. home surveys, employee eg. service records).
4 How we use and share personal information with suppliers
We will only use and share personal information where it is necessary for us to lawfully carry out our business activities eg. packaging supplier’s box delivery direct to a client’s house. We will not use and share personal information with suppliers on any other basis.
5 Sharing with third parties
5.1 We will not share personal information with anyone outside J. A. Coles (Removal Contractors) Limited except:
• where we have a person’s consent;
• where required for contract and or service procurement;
• where we are required by law and by law enforcement agencies, judicial bodies, government
entities, tax authorities or regulatory bodies;
• with third parties providing services to us, such as agents and sub-contractors acting on our behalf.
5.2 J. A. Coles (Removal Contractors) Limited will not share personal information with third parties for their own marketing purposes.
6 Transferring information overseas
6.1 In order to honour an overseas contract, we will transfer only relevant personal information to organisations in other countries. Such information includes documents for customs clearance (such as passport and visa copies), and delivery (such as contact details and inventories).
6.2 In the event that we transfer information outside the United Kingdom to within the European Economic Area (EEA), it will only be on the basis that anyone to whom we convey it to protects it in the same way we would and in accordance with the applicable laws of the EEA.
6.2 In the event that we transfer information outside the EEA, it will only be on the basis that anyone to whom we convey it to protects it in the same way we would and in accordance with the applicable laws of the land.
6.3 J. A. Coles (Removal Contractors) Limited maintains a right to audit compliance of designated suppliers and third parties, but cannot be held responsible for external privacy policies nor practices.
7 Marketing information
We will not send a person any marketing information relating to products and services unless they request us to do so.
8 Communications about personal records
8.1 We will contact a person with information relevant to their context within our business and operations including maintenance of personal contracts and accounts.
8.2 Communication may be by a variety of means including email, text message, post and/or telephone.
8.3 To maintain correct lines of communication, it is a person’s obligation to advise us immediately of any changes to their contact details.
8.4 We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes of secure data processing to protect both a person and us.
9 False information
9.1 If false or inaccurate information is provided to us and/or fraud is identified or suspected, details will be passed on to relevant organisations such as the fraud prevention agencies, and law enforcement agencies.
9.2 If a person supplies us with false information, we may refuse to offer services requested, or we may stop providing existing services.
10 How long we keep information
10.1 By providing a person with contracts, products or services, we create records that contain personal information (see section 2).
10.2 Records can be held on a variety of media (physical or electronic) and formats. Relevant records will be held securely by either physical means, such as documents under lock and key, or by electronic means, such as encryption technology.
10.3 We manage our records to help us to serve our customers and employees well and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities.
10.4 Retention periods for records are determined based on the type of record, the nature of the activity, product or service, the country of contracted destination plus the applicable local legal or regulatory requirements. We normally keep client records for up to six years after any relationship with us ends. Other records are retained for shorter periods eg. ten days for CCTV records.
10.5 Retention periods may be changed from time to time based on business or legal and regulatory requirements.
10.6 We may, by exception only, retain personal information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that we will be able to produce records as evidence, if they may be needed.
10.7 Expiration of records will implicate disposal methods applicable for confidential waste, such as shredding; incineration; electronic anonymisation; technical deletion.
11 Security
11.1 We are committed to ensuring that personal information is secure with us and with the third parties who act on our behalf.
11.2 We will ensure access to personal information is restricted to employees working within our company on
a need to know basis.
11.3 We will ensure appropriate measures are in place to protect personal information from loss, misuse, unauthorised access and disclosure.
12 A person’s freedom and rights
12.1 A person has a number of legal rights to control what we do with their personal information:
Access – a person has a right to get access to the personal information we hold about them by contacting us in writing.
Rectification – a person has a right to rectification of inaccurate personal information, and to update personal information, by contacting us in writing.
Restriction/Deletion – a person has a right to request restriction and or deletion of personal information if:
• we no longer need to process personal information for the purposes for which it was originally provided;
• we have requested permission to process personal information but that person wishes to withdraw their consent;
• we are not using personal information in a lawful manner.
Please note that in some cases, by asking us to do the latter it may mean that we are no longer able to provide a person with contracts or services.
Objection/Complaint – a person has a right to make an objection and or lodge a complaint concerning our processing of their personal information by contacting us in writing.
12.2 We actively review our policies to ensure they use clear plain language, thus remaining transparent. We actively update our policies by risk assessing any new processes or technologies, thus maintaining good practice. We ensure our policies are accessible. All our staff are made aware of our policies and as such are compliant in terms of their personal information as well as a client’s. We are open to resolve any issues that may arise, but further GDPR guidance can be obtained by contacting the Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow SK9 5AF Tel: 0303 123 1113 or 01625 545 745 www.ico.org.uk