It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation (GDPR), which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Allgood plc and other companies in its group including Allgood Trio Limited and Allgood Manufacturing Limited|
|Personal information||Any information relating to an identified or identifiable individual|
|Special category personal information||Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation|
The GDPR specifies that all personal data we hold must be:
We have considered our obligations under the GDPR (and in line with guidance from the Information Commissioners Office) and take these obligations seriously, for example:
We may collect and use the following personal information about you:
This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:
automated monitoring of our websites and other technical systems, such as our computer networks and connections, cctv and access control systems, communications systems, email and instant messaging systems;
Under GDPR, we can only use your personal information if we have a proper reason for doing so, eg:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide products and/or services to you||For the performance of our contract with you or your organisation or to take steps at your request before entering into a contract|
|To prevent and detect fraud against us, you or your organisation||For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you|
|Ensuring business policies are adhered to, eg policies covering security and internet use||For our legitimate interests, ie to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests to be as efficient as we can|
|Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests, ie to be as efficient as we can|
|Updating and enhancing customer records||For the performance of our contract with you or your organisation or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations For our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you|
|External audits and quality checks, eg for ISO||For our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations|
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell it to other organisations outside the group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by contacting us at firstname.lastname@example.org or select the unsubscribe option on emails you receive: We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
We routinely share personal information with:
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
We will keep your personal information while you have an account with us or we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg with your and our service providers located outside the EEA;
These transfers are subject to special rules under European and UK data protection law.
Some non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.
If you would like further information, please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
Access The right to be provided with a copy of your personal information (the right of access) Rectification The right to require us to correct any mistakes in your personal information To be forgotten The right to require us to delete your personal information—in certain situations Restriction of processing The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data Data portability The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests. Not to be subject to automated individual decision-making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 25 May 2018 and last updated on 25 May 2018.
We may change this privacy notice from time to time—when we do we will post a new version on our website. You should check this page periodically to ensure that you are happy with any changes.
Our contact details are shown below:
Our contact details
Post: GDPR Compliance, Allgood plc, 63-83 Brearley Street, Birmingham B19 3NT