1 What is the purpose of this document?
1.1 This Privacy Notice describes how we collect and use your personal information during and after your business relationship with us. We are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you and explaining it clearly to you.
1.2 This notice applies to prospective, current and former customers and suppliers.
1.3 It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
1.4 We reserve the right to update this privacy notice at any time, and we will make a new privacy notice available to you on this website or by request when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
1.5 We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at firstname.lastname@example.org.
2 How do we collect information about you?
2.1 We will collect data regarding you or your organisation, however there may be instances where we may collect personal information direct from you when you apply to open an account either as a customer or a supplier with us, and in the course of this service-related activities throughout the period of this business relationship and beyond where required by law, as set out in more detail, below.
2.2 We also collect information about supplier and customers from third parties, such as credit reference agencies or other background check agencies, Company House, as well as online information regarding you and the company you represent. All new accounts are subject to status and satisfactory credit assessment; in order to progress with your application we will make a search with a credit reference agency when required.
2.3 Occasionally, we may collect information about you from public sources, including social media sites such as Linked-in, Twitter, Instagram if we deem it necessary in order to conduct business with you.
What information do we hold?
2.4 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2.5 We will collect, store and use the following categories of personal information about you:
2.5.1 Your name, date of birth and your home address.
2.5.2 Your contact details (e.g. email address, phone number, your mobile numbers where you have provided this to us instead of your business mobile number).
2.5.3 Your bank details and trade and credit references.
2.5.4 Your photographs or video or visual recording taken or received with your consent.
2.5.5 CCTV footage when visiting our clinic premises.
2.5.6 In some instances we may request personal information which is deemed to be sensitive personal data (or special category data) such as pictures of your face. Inadvertently this information may identify you and exhibit medical conditions. This information may be shared with third parties such as our suppliers with your consent if further information is required to assist your condition. The information may also be used for marketing purposes on our website, leaflets or social media platforms but will only be done with your written consent.
3.1 If you fail to provide certain information when requested, we may not be able to carry out the business transactions and perform our obligation with you (such as selling or buying goods from you), or we may be prevented from complying with our legal obligations with our regulators.
3.2 It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your business relationship with us. Please inform the DPO of any such changes in writing.
4 How we will use information about you
4.1 We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
4.1.1 Where we need to perform the contract we have entered into with you, including processing and storing your orders ( for customers) or our purchase orders (for suppliers).
4.1.2 Where we need to comply with a legal obligation.
4.1.3 Where it is necessary for our legitimate interests (or those of a third party) and your interests and your fundamental rights do not override those interests. From time to time we may send you information that may be of interest to you to improve our business relationships such as special offers and information
4.2 We may also use your personal information in the following situations, which are likely to be rare:
4.2.1 Where we need to protect your interests (or someone else’s interests).
4.2.2 Where it is needed in the public interest.
4.2.3 In exceptional circumstances with your consent.
4.3 Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. Where we rely on legitimate interests these legitimate interests are:
4.3.1 To ensure the smooth running of our business relationship with you.
4.3.2 To allow us to process your enquiries and commercial transactions with us.
4.3.3 Managing our contractual relationship with you and to allow you to manage your relationship with us.
4.4 We use your personal information as follows:
4.4.1 We may use your name, contact or email address to contact you as part of dealing with business matters such as ordering, customer service matters, product quality complaints, feedback and other business related communications.
4.4.2 There may be instances such as, when dealing with customer service matters or product quality complaints, we may share your personal information with third parties such as suppliers and manufacturers in order that such matters get resolved with the minimum possible delay.
4.4.3 As a business to commerce organisation we use the Business Data for: business management and planning, including accounting and auditing;
4.5 We monitor and process the emails to us and use them as an audit trail for communication to assist us in the contract with customers and suppliers.
4.6 We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
4.7 Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. However, where consent is the only ground we have to process your personal data we will seek this from you.
5 How we use particularly sensitive personal information
5.1 Special categories of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
5.1.1 In limited circumstances, with your explicit written consent.
5.1.2 Where we need to carry out our legal obligations and in line with our data protection policy.
5.1.3 Where it is needed in the public interest.
5.2 Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
5.3 We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of contract law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
5.4 We will use your particularly sensitive personal information in the following ways:
5.4.1 In the course of our legitimate interests where we feel we need to adapt communications channels that will enable us to conduct our business with you.
5.4.2 To meet our legal obligation with regard to various legislations such as disability discrimination act.
5.4.3 To enrich your customer and supplier experience with us ( for example as described in paragraph 2.5.6 above).
6 Information about credit
6.1 We may only use information relating to credit references where the law allows us to do so, or where such processing is necessary for our legitimate and legal interests such Quality and Regulatory purposes.
6.2 Your information may need to be shared with third parties and regulatory bodies during and for the purposes of audits.
7 Data sharing
7.1 We will share your personal information with third parties where required by law, where it is necessary to administer the business relationship with you or where we have another legitimate interest in doing so.
7.2 All our third-party service providers are required to take appropriate security measures to protect your personal information in line with GDPR. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.
7.3 We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business.
8 Data security
8.1 We have put in place measures to protect the security of your information. Details of these measures are available upon request.
8.2 Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure and in line with GDPR requirements and legislation.
8.3 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who as business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality and conform to GDPR requirements and legislation.
8.4 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
9 How long will we use your information for?
9.1 We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
9.2 To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
9.3 Once you are no longer a customer or a supplier we will retain and securely destroy your personal information in accordance with our Data Retention Policy. In some cases, and only when it is absolutely necessary, we may retain your personal information following termination of our business and contractual relationship.
9.4 In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
9.5 Where a minimum retention period is required by law (such as retaining records for HMRC purposes) we comply with that minimum period plus up to 3 months to allow time for us to anonymise or delete information in accordance with our internal data management processes.
9.6 Copies of all electronic data created on our systems is retained our back up service provider for 10 years.
10 Your rights in connection with personal information
10.1 Under certain circumstances, by law you have the right to:
10.1.1 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.
10.1.2 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.
10.1.3 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).
10.1.4 Object to processing of your personal information where we are relying on a legitimate interest (or those of a 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.
10.1.5 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.
10.1.6 Request the transfer of your personal information to another party.
10.1.7 Withdraw consent in the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we are required to continue to process your information in accordance with another lawful basis which has been notified to you.
10.2 To exercise any of the above rights, please contact the DPO in writing or by email- details to be found in paragraph 1.5 above.
10.3 You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
10.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If you have any questions about this privacy notice, please contact the DPO.
We are committed to protecting your Privacy. We will only use the information that we collect about you lawfully (in accordance with the latest GDPR law 2018).
We will not e-mail you in the future unless you have given us your consent. We will give you the opportunity to refuse any marketing e-mail from us or from a 3rd party in the future.
You can check the information we hold about you by e-mailing us. If you find any inaccuracies, we will amend/delete them as appropriate.
The personal information we hold will be held securely in accordance with our internal security policy and UK law. If we intend to transfer your information outside the EEC (European Economic Area), we will obtain your permission first.
If you have any questions/comments about Privacy, you should e-mail us at: email@example.com
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