DATA PROTECTION POLICY
Torquay Watersports Ltd, Registered in England under Company Number 12040564
Registered Address: 1 Linhey Close, Kingsbridge, Devon TQ7 1LL
Email Address: firstname.lastname@example.org, Telephone Number: 01803 362122
Postal Address: Torquay Marina, Vaughan Road, Torquay, Devon TQ2 5EQ
1. What does the policy cover?
2. Policy Statement
3. Who is covered by the policy?
5. Data Collection
6. Data Use
7. Data retention and data breach
- What does the policy cover?
1.1 Torquay Watersports Ltd takes the responsibility of data security very seriously, including the personal data we collect during our working practices.
1.2 This policy provides a source of information and guidance, defining the personal data Torquay Watersports Ltd collect, explaining how we use, disclose, transfer and store the data we hold.
- Policy Statement
2.1 Torquay Watersports Ltd is committed to processing personal data fairly and lawfully in accordance with individuals’ rights. We are bound by the laws of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).
2.2 Torquay Watersports Ltd will collect and process personal information in order to provide services and special events, we also use personal data to provide and acquire quotes and respond to enquiries.
2.3 This policy supplements our other policies which are available on request.
- Who is covered by the policy?
3.1 The policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), no matter where they are located (within or outside of the UK). 3.2 In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, potential employees, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.
3.3 Any arrangements our company makes with a third party is subject to clear contractual terms.
4.1 ‘Personal Data’ relates to a person’s private, professional or public life. A non-exhaustive list of personal data includes name, address, email address, I.P. address, phone number, fax number.
4.2 ‘Sensitive Personal Data’ refers to a person’s racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health or details of criminal offences.
4.3 ‘Biometric Personal Data’ relates to a person’s personal data resulting from a specific technical process. A non-exhaustive list could include photographs, photographic ID, CCTV images and recorded telephone conversations.
4.4 The ‘Data Subject’ is an identified or identifiable natural person, i.e. you.
4.5 Torquay Watersports Ltd are responsible for the control of the data processed and are defined as the ‘Data Controller’
4.6 Torquay Watersports Ltd may provide personal information to third-parties who are known as ‘Data Processors’. Torquay Watersports Ltd remain responsible for any breach of Data Protection brought about by the Data Processor.
4.7 ‘Legitimate Interest’ Torquay Watersports Ltd may not require explicit consent to process personal data as we have a legitimate interest to fulfil or obtain contracts with our clients, suppliers and employees. Torquay Watersports Ltd also have a responsibility to the security and protection of our products and services as well as the individuals defined in section 3 of this policy.
- Data Collection
5.1 Torquay Watersports Ltd will ensure that any personal data is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained (e.g. to fulfil a contract).
5.2 In the rare cases where we process sensitive personal data we will require the data subject’s explicit consent to do this unless exceptional circumstances apply or where we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any consent will clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.
5.3 Consent can be revoked at any time, preferably by email or in writing, although this may mean that Torquay Watersports Ltd may no longer be able to provide a service or continue to employ an individual.
5.4 Individuals have a right to rectify personal data Torquay Watersports Ltd holds. If it is believed information we hold is inaccurate, or the data we hold needs to be updated, please email the Torquay Watersports Ltd.
5.5 Individuals have a right to access the personal data Torquay Watersports holds. If you would like to obtain information about yourself held by Torquay Watersports Ltd, please send a request detailing the information or processing activity to which the request relates, quoting DSAR (Data Subject Access Request). We ask that the request is specific to a date/time, clearly detailing a description of the type of data you want to have access to in order for us to acquire the information effectively and within one month of receipt of the request.
5.6 Torquay Watersports Ltd are committed to the security of our services, we therefore request that any request for personal data includes two forms of identification which can include a Passport, Driving Licence, Birth Certificate, utility Bill (from the last 3 months), Current Vehicle Registration form, Bank Statement (from the last 3 months) or rent book (from the last 3 months). In certain instances, we will freely provide information after a full risk assessment.
5.7 A Data Subject has the ‘Right to Erasure’ and may request that the information held on them is deleted in accordance with regulatory procedures. Once erased, we will no longer be able to provide services to the individual, this should not affect the company employing the individual (e.g. we can delete the name, email address and mobile telephone number of someone no longer employed by a client). Please send requests by email with the subject header ‘Erasure request’ to Torquay Watersports Ltd.
5.8 Torquay Watersports Ltd do not collect, trade, sell or profile personal data for marketing purposes.
5.9 Emails sent to Torquay Watersports Ltd are not encrypted unless both the sender and the receiver have a matching encryption key, therefore we cannot guarantee the confidentiality of the information you provide by email.
- Data Use
6.1 Torquay Watersports Ltd will use your personal data to provide or acquire services, offer online content (via our website), to offer and respond to enquiries.
6.2 Torquay Watersports Ltd website contains hyperlinks to third-party websites. The third-party websites have their own privacy policies, we recommend you review them to understand how they handle your personal information. Torquay Watersports Ltd accept no responsibility or liability for the privacy practices of third-party websites and use of them is entirely at your own risk.
6.3 For online bookings and purchases, credit card information used by Torquay Watersports Ltd is processed in accordance with the Payment Card Industry Data Security Standard (PCI DSS), to which we are fully compliant.
6.4 Social Media – If you use any of our social network pages or applications or you use one of our products or services that allow interaction with social networks, we may receive information relating to your social network accounts. For instance: If you click on a ‘like’, ‘+1’ or ‘tweet’ or similar button in one of our websites or services, we may record the fact that you have done so. In addition, the content that you are viewing may be posted to your social network profile or feed. We may receive information about further interactions with this posted content (for example, if your contacts click on a link in the posted content), which we may associate with the details that we store about you. If you ‘like’, ‘+1’ or similar one of our pages on a social network site, we may receive information about your social network profile, depending on your social network account privacy settings.
6.5 Reviews, comments and content – Where you have uploaded product reviews, comments or content to our websites or services and made them publicly visible, we may link to, publish or publicise these materials elsewhere including in our own advertisements.
- Data Retention and Breach
7.1 Personal data will be held for as long as necessary for the relevant activity or until such time we receive a request to erase the data we hold.
7.2 Torquay Watersports Ltd will ensure all systems, software and equipment exceed acceptable security standards.
7.3 In cases where data is stored on printed paper, it is kept in a secure place where only authorised personnel have access for no longer than 7 years.
7.4 Printed data is shredded after the retention period has ended.
7.5 Data stored on a computer is protected by strong passwords which are regularly changed, in certain circumstances data is encrypted.