P C Tonkin & Son Limited PRIVACY POLICY
Version 1
CONTENTS
CLAUSES SUBJECT PAGE NO.
1. INTRODUCTION AND TERMS
2. WHO WE ARE AND HOW TO CONTACT US
3. THE DATA WE COLLECT ABOUT YOU
4. HOW YOUR DATA WILL BE USED
5. THIRD PARTIES
6. WHERE YOUR DATA IS HELD
7. LEGITIMATE INTEREST & MARKETING
8. APPLICATIONS TO WORK FOR US
9. DATA RETENTION
10. YOUR RIGHTS
11. CHANGES
12. COMPLAINTS
1. INTRODUCTION AND TERMS
P C Tonkin & Son Limited ("We" or "us") are committed to protecting and respecting your personal data and privacy. This privacy policy relates to our use of any personal data we collect from you from any of our services. Whenever you provide such information, we are legally obliged to use your information in line with all applicable laws concerning the protection of personal data; including the Data Protection Act 1998 and 2018 (DPA) and The General Data Protection Regulation 2016 (GDPR) together, and with other subsequent laws "Data Protection Laws".
2. WHO WE ARE AND HOW TO CONTACT US
2.1 For the purpose of the Data Protection Laws, the data controller is P C Tonkin & Son Limited, registered company number 06045880. If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below:
- FAO: Privacy Officer
- 77 Fore Street, Bugle, St Austell, Cornwall, PL26 8PD
- Email: nigel.tonkin@pctonkin.co.uk
- Telephone: 01726850241 and ask to speak to the Privacy Officer
3. THE DATA WE COLLECT ABOUT YOU
3.1 We collect and process Personal Data. Typically the Personal Data we collect and process will include name, address and email address but we may collect and/or process other Personal Data from time to time. It also may include IP address and cookies of your visit to websites.
3.2 We only collect data from you directly or via third parties (see Third Parties below).
4. HOW YOUR DATA WILL BE USED
4.1 We use information held about you to:
4.1.1 carry out our obligations arising from any contracts entered into between you and us;
4.1.2 provide you with information, products or services that you request from us or which we feel may interest you (where you have consented to be contacted for such purposes or where we have identified a Legitimate Interest);
4.1.3 carry out necessary maintenance to our infrastructure; and
4.1.4 notify you about changes to our services
4.2 We also embrace the use of social media and may wish to process any comments made public by you.
5. THIRD PARTIES
5.1 We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you. We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
5.2 Please see below the list which sets out the categories of recipients of personal data.
- SERVICE PROVIDED
- IT Support Services
- Email Provider
- Secure document disposal service
- Internal HR systems provider
- Marketing Companies (Service Reminders etc.)
- Banks
- Email marketing platforms
- Vehicle Finance Companies
- Accountants
- Solicitors
5.3 In addition third parties may provide us with Personal Data and they should only do so where the law allows them to.
6. WHERE YOUR DATA IS HELD
6.1 Your data is stored by us and our processors in the UK and EEA. We have adopted appropriate measures both organisationally and technically to protect the personal data we collect and use having regard to the state of the art, the nature of the data stored and the risks to which the data is exposed to human action or the physical or natural environment. However, as effective as our security measures are, it is to be accepted that no security system is impenetrable. Therefore we are not able to guarantee the security of our database.
6.2 The transmission of information via the internet is not completely secure. We will endeavour to protect your personal data, however we cannot fully guarantee the security of data transmitted to our website. Therefore any transmission will be at your own risk. On receipt of your information, we will use procedures and security features to attempt to prevent unauthorised access.
7. LEGITIMATE INTEREST & MARKETING
7.1 Where we use Legitimate Interests we will record our decision and our method on making this decision.
7.2 If you are an existing contact or customer we will only contact you by postal and electronic means (e-mail) with information about services or goods which you have previously purchased from us or enquired about. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by post or electronic means only if you have consented to this. You can choose to not receive these types of communication by contacting us.
8. APPLICATIONS TO WORK FOR US
If you apply to work for us (directly or indirectly) in any role (including volunteers) we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.
9. DATA RETENTION
Our data retention policy is dictated by the Data Protection Laws and is available for inspection by submitting a written request using the contact details provided in this policy.
10. YOUR RIGHTS
10.1 Under the Data Protection Laws your rights are:
10.1.1 To be informed – We must make this privacy policy (sometimes referred to as a privacy notice) available with the emphasis on transparency over how we process your data.
10.1.2 Access – You are entitled to find out what details we may hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their Personal Data by making a formal request under the Data Protection Laws. Such requests should be in writing to the contact details provided in this policy. In the instance that we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy). The information we supply will:
(a) confirm that your data is being processed;
(b) verify the lawfulness and the purpose of the processing;
(c) confirm the categories of personal data being processed;
(d) confirm the type of recipient to whom the personal data have been or will be disclosed; and
(e) let you have a copy of the data in an intelligible form.
10.1.3 Rectification – We are obliged to correct or update your details. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.
10.1.4 Erasure – This is also known as the request to be forgotten. Under Data Protection Laws you have the right to erasure under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and should be submitted in writing to the contact details provided in this policy.
10.1.5 Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.
10.1.6 Portability – You have the right to obtain and reuse your personal data that you have provided to us.
10.1.7 Object – You have the right to object to us processing your data in relation to direct marketing and or profiling.
10.1.8 Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.
10.2 Please note that you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the Data Protection Laws and as summarised above.
10.3 If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone
11. CHANGES
We keep our privacy policy under regular review and you should check back regularly to ensure you are aware of changes to it. We may display this notice to you from time to time to help ensure you are aware of its contents.
12. COMPLAINTS
You have the right to complain about the processing of your personal data. Please contact us using the details provided above. If you are still unsatisfied you have the right to complain to the Information Commissioners Office.