Updated October 2018.
Sarum Hydraulics understands that your privacy is important to you and that you care about how your personal data is used and stored and We will collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings: “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to as part of daily business duties. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and “We/Us/Our” means Sarum Hydraulics Limited, a limited company registered in England under company number 3037960, whose registered office address is 43 Albany Road, Salisbury SP13YQ, UK. Our place of business is Unit 1, Danebury Court, Old Sarum Park, Old Sarum, Salisbury, Wiltshire, SP4 6EB, UK.
2. Information About Us
- Sarum Hydraulics Limited, Unit 1, Danebury Court, Old Sarum Park, Old Sarum, Salisbury, Wiltshire, SP4 6EB. Tel: 0044 (0) 1722 328388.
- Our VAT number is GB619992291
- Our representative for Data Protection issues is John Foster (Managing Director), who can be contacted by email at firstname.lastname@example.org, by telephone on 0044 (0)1722 328388, or by post at the above address.
- Our website www.sarum-hydraulics.co.uk is owned and operated by Sarum Hydraulics Ltd.
3.What Does This Policy Cover?
4. Your Rights
- As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data
- The right of access to the personal data We hold about you (see section 12)
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13)
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13)
- The right to restrict (i.e. prevent) the processing of your personal data
- The right to data portability (obtaining a copy of your personal data to reuse with another service or organisation)
- The right to object to Us using your personal data for particular purposes
- Rights with respect to automated decision making and profiling.
- If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office via the website www.ico.org.uk
- For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5.What Data Do We Collect?
We may collect some or all of the following personal data:
- Your name
- business/company name
- contact information such as job title, email and postal addresses and telephone numbers
- bank account and payment details, including credit cards for one time use only
- transactional information regarding goods sold or purchased, payment method, time and date of purchase.
6. How Do We Use Your Data?
- All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
- Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests.
- Specifically, we may use your data for the following purposes:
- Supplying Our services to you
- Supplying products to you which you have purchased from us (please note that We require your personal data in order to enter into a contract with you)
- Replying to emails from you
- Supplying you with emails. You may unsubscribe or opt-out at any time when communications relate to commercial activities by using the link at the foot of each email, or by contacting John Foster by email at email@example.com
- Market research.
- With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email with information, news, and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
- You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
- We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- The contact details of Our customers and suppliers for the purposes of maintaining an ongoing business relationship, to be retained for the period in which We have a legitimate interest to hold the data, or until the individual requests removal
- Details of sales and purchase transactions, to be held for six years as required under financial regulations
- Details of sales via our website, to be held for six years as required under financial regulations
- Retention of job candidate details for one year or until the candidate requests their removal
7. How and Where Do We Store Your Data?
- We only keep your personal data for as long as We need to in order to use it as described above in section 6, unless you instruct us to act otherwise.
- Although We will only store your data within the UK, we do use external companies to process data on our behalf, such as MailChimp for sending emails. Some of our partners may store your personal information outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). They will process your data only under documented instruction from Us, and have no rights to use your data for any other purpose. You are deemed to accept and agree to this by using Our services, and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
- Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
- Steps We take to secure and protect your data include:
- Storing data on up-to-date and secure servers, with antivirus software, firewall and anti-malware software protection
- Encrypting and/or password protecting the systems on which your data is stored
- Ensuring that only staff of the Company and its data processors have access to your data
- Providing training to our staff on data protection
- Ensuring that the systems on which your data resides are backed up regularly in a secure way and are encrypted
- Ensuring that the systems on which your data resides are subject to appropriate technical security measures
- Any printed documentation is kept securely within our premises.
8. Do We Share Your Data?
- We may share the data of our membership with other organisations as part of our efforts to promote the products and services of our members. We will do so according to the information in our Articles of Association, and on the lawful basis of “Legitimate Interests” as We believe it is in our interests and those of our members to promote the services and products of our membership.
- We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of marketing and communication emails, and delivery of goods which you purchase from us. In some cases, the third parties may require access to some of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
- We may sometimes use third party data processors, including those listed below, some of which may be located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
- MailChimp (under the EU / US Privacy Shield)
- Web development and hosting companies (within the UK, or in the USA under the EU / US Privacy Shield)
- In certain circumstances, we may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
- In the event that any of your data is to be transferred in such a manner, we will endeavour to contact you in advance to inform you of the changes. When contacted you may be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
- In addition to your rights under the GDPR, set out in section 4, you may be given options to restrict Our use of your data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
You may access certain areas of Our websites without providing any data at all. However, to use all features and functions available on Our websites you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org, or using the contact details below in section 13.
13. Contacting Us
Our formal Job Applicant Privacy Notice
During the recruitment process, Sarum Hydraulics Limited (the Company) collects and processes personal data relating to job applicants. The Company is committed to being clear and transparent about how it collects and uses that data and to meeting its data protection obligations.
The data controller is Sarum Hydraulics Limited of 43 Albany Road, Salisbury, Wiltshire, United Kingdom, SP1 3YQ (“we”, “us” or “our”). Details of our notification to the data protection regulator may be found in the Information Commissioner’s Office Public Register of Data Controllers at ico.org.uk.
What information does the Company collect and process?
The Company collects and processes a range of personal information (personal data) about you. Personal data means any information about an individual from which the person can be identified. This includes:
- Personal contact details, such as your name, title, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers;
- information about your remuneration, including entitlement to benefits such as pensions;
- information about your entitlement to work in the UK; and
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
The Company collects this information in a variety of ways during the application and recruitment process. For example, data may be contained in application forms and CVs, obtained from identity documents, such as your passport and collected through interviews and assessment tests.
The Company may collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks permitted by law.
Data is stored in a range of different places, including the third party on line recruitment systems upon which you may apply; on your application record; in the Company’s HR management systems; in and in other IT systems including the Company’s email system.
Why does the Company process personal data?
The Company needs to process data prior to entering into a contract with you. We also need to process data to enter into an employment contract with you and to meet our obligations under that employment contract.
In addition, the Company needs to process data to ensure that we are complying with our legal obligations. For example, we are required to check an employee’s entitlement to work in the UK before employment begins.
The Company has a legitimate interest in processing personal data during the recruitment process and in keeping records of that process. Processing such data from job applicants enables the Company to manage the recruitment process, assess the suitability of candidates and make informed decision as to whom we wish to recruit. The Company may also have to process data from job applicants in order to defend legal claims.
The Company processes health information if we need to make reasonable adjustments to the recruitment process for candidates with a disability.
If you fail to provide personal information
You are under no obligation to provide the Company with data during the recruitment process. However, if you do not prove certain information when requested, the Company may not be able to process your application for employment properly or at all.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for you if this information is not provided.
Our employment decisions are not based solely on automated decision-making.
For how long do you keep data?
The Company will only hold your personal data for as long as is necessary to fulfil the purposes for which we collected it. If your application for employment is unsuccessful, the Company will hold your data on file for one year after the end of the recruitment process. At the end of that period, your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and we shall issue a new privacy notice which sets down the periods for which your data will be held.
Who has access to data?
Your information will be shared internally for the purposes of the recruitment process, including with the Recruiting Manager; the Directors and our HR Consultants carrying out work on our behalf.
The Company will not share your data with third parties unless we make you an offer of employment. In those circumstances, the Company shall share your data with third parties where required by law and where it is necessary in order to administer the working relationship with you or where we have another legitimate interest in doing so. The Company will then share your data with:
- our professional advisers, such as our HR Consultant; Accountants and legal advisers, where they require that information in order to provide advice to the Company;
- HM Revenue & Customs and any other regulatory authority we may be subject to for the purpose of demonstrating compliance with applicable law and regulations;
- such third parties as we reasonably consider necessary in order to prevent crime, such as the police;
- our service providers such as our pensions and benefits providers and payroll administrators, as well as those who provide and support our management and data storage systems.
The Company will not transfer your data to countries outside the European Economic Area.
How does the Company protect data?
The Company takes the security of your data seriously. The Company has internal controls in place to prevent your data being lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request (known as a “data subject access request”);
- require the Company to change incorrect or incomplete data;
- request erasure of your personal information. This enables you to ask the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where the Company is relying on its legitimate interests as the legal ground for processing; and
- ask the Company to suspend the processing of your personal data for a period of time if data is inaccurate or there is a dispute about its accuracy or the reason for processing it.
If you would like to exercise any of these rights, or you have any questions about the privacy notice, please contact us by using the contact details on our website.
If you believe that the Company has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office.