PRIVACY STANDARD Introduction This Privacy Standard sets out how we handle the Personal Data of our customers, suppliers, employees, workers and other third parties. It is intended to incorporate our obligations under the General Data Protection Regulation (“GDPR").
This Privacy Standard applies to all Company Personnel and sets out what we expect from our staff in order for us to comply with the law in this area. Our staff's compliance with this Privacy Standard is mandatory. Any breach of this Privacy Standard may result in disciplinary action.
What is “Personal Data”?
When we talk about Personal Data, we are referring to any information which identifies or relates to an individual, for example a name, address, date of birth or email address. It also includes sensitive personal data, for example racial or ethnic origin, religious beliefs, sexual orientation or physical or mental health conditions.
What is “Processing” Personal Data?
We will mention process or processing Personal data in this Standard. By that we mean any activity that involves the use of Personal Data. It will include obtaining, recording or holding the data and also covers transferring the data to third parties (for example insurance providers or IT companies).
Scope Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times.
All departments are responsible for ensuring all Company Personnel comply with this Privacy Standard and need to implement appropriate practices, processes, controls and training to ensure such compliance.
The HR manager and directors are responsible for overseeing this privacy standard and, as applicable, developing related policies and privacy guidelines which you will be provided or notified of where relevant.
Please contact the HR manager with any questions about the operation of this Privacy Standard or the GDPR or if you have any concerns that this Privacy Standard is not being or has not been followed. In particular, you must always contact the HR manager if you have concerns about whether we are complying with the Personal Data Protection Principles set out below.
Personal data protection principles We adhere to the principles relating to processing of Personal Data set out in the GDPR which require Personal Data to be:
Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).
Accurate and where necessary kept up to date (Accuracy).
Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed (Storage Limitation).
Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).
Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
Made available to data subjects and data subjects are allowed to exercise certain rights in relation to their Personal Data (Data Subject’s Rights and Requests).
We are responsible for and must be able to demonstrate compliance with the data protection principles listed above.
Lawfulness, fairness, transparency
Lawfulness and fairness Personal data must be processed lawfully, fairly and in a transparent manner in relation to the Data Subject. You may only collect, process and share Personal Data fairly and lawfully and for specified purposes some of which are set out below:
the Data Subject has given his or her consent.
In order to obtain relevant consent, an individual must indicate agreement clearly either by a statement or positive action. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If consent is given in a document which deals with other matters, then the consent must be kept separate from those other matters.
We may ask our customers, employees, suppliers and workers for consent in various forms and for various reasons. We also provide the opportunity for individuals to easily withdraw consent at any time.
Depending on your role you may be required to capture consent from customers.
the Processing is necessary for the performance of a contract with the data subject;
to meet our legal compliance obligations;
(d) to protect the data subject’s vital interests; or
to pursue our legitimate interests for purposes where they are not overridden because the processing prejudices the interests or fundamental rights and freedoms of data subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices.
Personal Data must be collected only for specified, explicit and legitimate purposes. We therefore only request personal data required to ensure successful business operations. For example, if you have received a customer’s consent to send marketing emails to them about plants you cannot send marketing emails to them about DIY products.
Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed. You may only process Personal Data when performing your job duties requires it. You cannot process Personal Data for any reason unrelated to your job duties. You may only collect Personal Data that you require for your job duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes. If you are unsure as to the reason or purpose for collecting Personal Data please speak to your manager or the HR Department. You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company’s data retention guidelines.
Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate. Where applicable to your role, you must ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data. If you have any concerns regarding the accuracy or updating our customer records, please contact a Director. For employee records please contact the HR Department.
Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed. The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires such data to be kept for a minimum time. You will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all the Company’s applicable data retention policies. This includes requiring third parties to delete such data where applicable. Before erasing, please check with your line manager. Where applicable to your role, you will ensure data subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice.
Security integrity and confidentialityprotecting personal data
Protecting Personal Data: Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful processing, and against accidental loss, destruction or damage. We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks. You are required to take responsibility for protecting the Personal Data we hold and you must exercise particular care when collecting and processing Personal Data to avoid loss and unauthorised access, use or disclosure. You must follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested. Prior to any such third-party transfer, please seek consent from your line manager. You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:
Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it.
Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed.
Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.
You must comply with all applicable aspects of our IT and Communications Policy. Reporting a personal data breach: We must notify any Personal Data Breach to the Information Commissioner and, in certain instances, the Data Subject. If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the HR manager or a director. You should preserve all evidence relating to the potential Personal Data Breach.
The GDPR restricts data transfers to countries outside the EEA in order to ensure that the level of data protection afforded to individuals by the GDPR is not undermined. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country. You may only transfer Personal Data outside the EEA in certain circumstances. Please contact the HR manager if cross border data transfers apply to your job duties.
Data Subject’s rights and requests
Data subjects have rights when it comes to how we handle their Personal Data. These include rights to:
withdraw consent to processing at any time;
receive certain information about our processing activities;
request access to their Personal Data that we hold;
prevent our use of their Personal Data for direct marketing purposes;
ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or processed or to rectify inaccurate data or to complete incomplete data;
restrict processing in specific circumstances;
challenge processing which has been justified on the basis of our legitimate interests or in the public interest;
request a copy of an agreement under which Personal Data is transferred outside of the EEA;
object to decisions based solely on automated processing, including profiling (ADM);
prevent processing that is likely to cause damage or distress to the data subject or anyone else;
be notified of a Personal Data breach which is likely to result in high risk to their rights and freedoms;
make a complaint to the supervisory authority; and
in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine-readable format.
You must verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade you into disclosing Personal Data without proper authorisation). You must immediately forward any Data Subject request you receive to the HR manager. Accountability We have adequate resources and controls in place to ensure and to document GDPR compliance including: (a) appointing a suitably qualified manager accountable for data privacy; (b) implementing appropriate measures when processing Personal Data and completing impact assessments where processing presents a high risk to rights and freedoms of data subjects; (c) integrating data protection into internal documents including this Privacy Standard, related policies and our Privacy Notices; (d) regularly training Company Personnel on the GDPR and this Privacy Standard; (e) regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance. Record keeping The GDPR requires us to keep full and accurate records of all our data processing activities. Where your role requires you to process Personal Data you must keep and maintain accurate records you collect or process during your duties. Training and audit We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance. You must undergo all mandatory data privacy related training where requested to attend and (where relevant) ensure your team undergo similar mandatory training. You must regularly review all the systems and processes under your control to ensure they comply with this Privacy Standard and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data. Privacy by design and data protection impact assessment (DPIA) We are required to implement privacy by design measures when processing Personal Data by implementing appropriate technical and organisational measures in an effective manner, to ensure compliance with data privacy principles. Where relevant to your role you must assess what privacy by design measures can be implemented on all programs/systems/processes that process Personal Data that you use. You should liaise with the HR manager and/or a director to conduct a DPIA when implementing major system or business change programs involving the processing of Personal Data. Direct marketing We are subject to certain rules and privacy laws when marketing to our customers. For example, a customer’s prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as “soft opt in” allows us to send marketing texts or emails if we have obtained contact details in the course of a sale to that person, we are marketing similar products or services, and we gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message. If a customer contacts you to raise an objection to direct marketing, this must be promptly actioned. Please report this to your line manager immediately. Sharing personal data Generally, we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place. You may only share the Personal Data we hold with another employee, agent or representative of our group if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions. You may only share the Personal Data we hold with third parties, such as our service providers (pension providers, insurance companies etc) if:
they have a need to know the information for the purposes of providing the contracted services;
sharing the Personal Data complies with our Privacy Notice;
the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
the transfer complies with any applicable cross border transfer restrictions; and
a fully executed written contract that contains GDPR approved third party clauses has been obtained.
If you are unsure as to whether the above criteria are satisfied, do not transfer the data to the third party until you have confirmed this with a director or the HR manager Changes to this privacy standard We reserve the right to change this Privacy Standard at any time without notice to you so please check back regularly to obtain the latest copy of this Privacy Standard. This Privacy Standard does not override any applicable national data privacy laws and regulations in countries where we operate.
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