On 25 May 2018, the General Data Protection Regulation (GDPR) will come into force and any organisation that works with EU residents’ personal data will be obliged to comply with its provisions.
Simpsons Malt Limited (we) are committed to treating individuals’ personal data in an appropriate and lawful manner, in accordance with the GDPR and we are the data controller.
Everyone has rights with regard to the way in which their personal data is handled and we recognise that the correct and lawful treatment of this data will maintain confidence in our organisation.
We are committed to complying with GDPR and our ongoing compliance efforts include:
Information we may collect from you
We are currently assessing the personal data that we hold, where it came from and who we share it with. We are using this information to update our policies, standard practices, governance and other documentation as required.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We are currently working on GDPR compliance, therefore will be amending this table soon. If you have any questions, please contact us.
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer and/or supplier||Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(b) Necessary to comply with a legal obligation
Information we receive from other sources: We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
Employee Training and Awareness
We are arranging appropriate training for relevant employees who process personal data on the GDPR, data privacy and security to ensure that your data is kept safely and securely
We are also reviewing our data breach management processes not only to prevent data breaches occurring but, should such a breach occur, to ensure that the tightest security measures and reporting procedures are in place to protect you and your data.
We (or one of our third-party suppliers) may transfer your personal data outside of the European Economic Area (EEA).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. However, the transmission of information via the internet is not completely secure. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We do not keep personal data for any longer than is necessary, or for any reason other than the purpose for which we collected it. We are in the process of preparing a retention policy, which outlines how long we keep personal data for.
Third Party Links
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Complain you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.