Privacy and Data Protection


PRIVACY NOTICE

GENERAL DATA PROTECTION REGULATION (GDPR)

Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd:

(“We”) are committed to protecting your personal information.

This privacy notice has been written to inform all our customers and partners about what we do with the personal information that we collect from you, or that you provide to us.

By providing information or corresponding with us by telephone, letter or email you are accepting and consenting to the practices described in our Data Protection policy.

Changes to this Privacy Notice

We may amend this Privacy Notice from time to time. If we make any substantial changes in the way we use your personal information we will make that information available by amending this notice.

We are registered with the Information Commissioner Office and comply fully with the General Data Protection Regulation (GDPR).

Further information is available from the Information Commissioner’s website: https://ico.org.uk/

We are, for the purposes of the Data Protection Act 1998 and as defined by Article 4 (7) of GDPR, registered as a “data controller” for personal data. This means that we determine the purposes for which, and the manner in which, your personal data is processed. We have a responsibility to you and your personal data and will only collect and use this in ways which are compliant with data protection legislation.

Information we collect

We collect anonymous website usage date through cookies which does not identify you in any way. We may collect and process the data you provide when entering an event or when you contact us by telephone, email or letter or by submitting invoices for payment.

Information may include:

  • Personal information e.g. name, DOB, address, email address, telephone numbers
  • Bank details and credit card details
  • Next of kin details including phone number

We may also process sensitive classes of information, including:

  • Medical conditions and allergies
  • Doctor’s details

Sharing data

Your data may be shared with third parties who work with us to ensure your safety. Organisations with whom we may share your information are

  • Medical safety teams
  • Tracking device teams

 

Hardmoors Hardwear Ltd

Other organisations with whom we may share your information for retail purposes are

  • Suppliers of clothing and other goods which are sent by post to you, the customer

Storing your personal data

All information collected by us about you is stored on our highly secure servers and is not transferred outside the European Economic Area (“EEA”).

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

Once we have received your information we will use strict procedures and security features to prevent unauthorised access.

Customer information is stored for accounting purposes only, electronically for 6 years in accordance with government guidelines.

Access to information

Under GDPR you have the following rights in relation to the processing of your personal data:

  • To be informed about how we process your personal data. This notice fulfils this obligation
  • To request access to your personal data that we hold and to be provided with a copy of it
  • To request that your personal data is amended if inaccurate or incomplete
  • To request that your personal data is erased where there is no compelling reason for its continued processing
  • To request that the processing of your personal data is restricted
  • To object to your personal data being processed

Marketing Information we store about you is not used for marketing purposes but purely to contact you regarding the service you have requested.

If you wish to be removed from our customer list or your details amended please contact Shirley Steele, Data Protection Officer.

 


Data Protection Policy

1. Introduction

Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd are committed to conducting business in accordance with all applicable Data Protection laws and regulations and in line with the highest standards of ethical conduct. This policy sets forth the expected behaviours of Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd and Third Parties in relation to the collection, use, retention, transfer, disclosure and destruction of any Personal Data belonging to Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd

Personal Data is any information (including opinions and intentions) which relates to an identified or Identifiable Natural Person. Personal Data is subject to certain legal safeguards and other regulations, which impose restrictions on how organisations may process Personal Data. An organisation that handles Personal Data and makes decisions about its use is known as a Data Controller. Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd, as Data Controllers, are responsible for ensuring compliance with the Data Protection requirements outlined in this policy. Non-compliance may expose Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd to complaints, regulatory action, fines, and/or reputational damage.

2. Scope

This policy applies to

  • The business activities of Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd
  • For the provision or offer of goods or services to individuals (including those provided or offered free-of-charge) This policy applies to all Processing of Personal Data in electronic form (including electronic mail and documents created with word processing software) or where it is held in manual files that are structured in a way that allows ready access to information about individuals. Where national law imposes a requirement, which is stricter than imposed by this policy, the requirements in national law must be followed. Furthermore, where national law imposes a requirement that is not addressed in this policy, the relevant national law must be adhered to. If there are conflicting requirements in this policy and national law, please consult with the Office of Data Protection for guidance.

3. Definitions

Employee – An individual who works part-time or full-time for Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd under a contract of employment, whether oral or written, express or implied, and has recognised rights and duties. Includes temporary employees and volunteers.

Third Party – An external organisation with which Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd conducts business and is also authorised to, under the direct authority of The Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd, Process the Personal Data of The Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd.

Personal Data – Any information (including opinions and intentions) which relates to an identified or Identifiable Natural Person.

Contact – Any past, current or prospective Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd customer.

 Identifiable Natural Person – Anyone who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data Controller – A natural or legal person, Public Authority, Agency, or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

Data Subject – The identified or Identifiable Natural Person to which the data refers.

Process, Processed, Processing – Any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means. Operations performed may include collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

Data Protection – The process of safeguarding Personal Data from unauthorised or unlawful disclosure, access, alteration, Processing, transfer, or destruction.

Data Protection Authority – An independent Public Authority responsible for monitoring the application of the relevant Data Protection regulation set forth in national law.

Data Processors – A natural or legal person, Public Authority, Agency, or other body which Processes Personal Data on behalf of a Data Controller.

Consent – Any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.

4. Policy

4.1 Governance

To demonstrate our commitment to Data Protection, and to enhance the effectiveness of our compliance efforts, Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd has an assigned Data Protection Officer. The Officer is one of the Company Directors. The officer is responsible for:

  • Informing and advising Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd and its employees who carry out Processing pursuant to Data Protection regulations, national law or Union based Data Protection provisions;
  • Ensuring the alignment of this policy with Data Protection regulations, national law or Union based Data Protection provisions;
  • Acting as a point of contact for and cooperating with Data Protection Authorities (DPAs);
  • The establishment and operation of a system providing prompt and appropriate responses to Data Subject requests;

 

4.2 Policy Dissemination & Enforcement

The Data Protection Officer for Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd must ensure that all Employees responsible for the Processing of Personal Data are aware of and comply with the contents of this policy. The Officer will be responsible for the effectiveness of Data Protection related operational practices, including:

  • Data Subject rights.
  • Personal Data transfers.
  • Personal Data incident management.
  • Personal Data complaints handling.
  • The level of understanding of Data Protection policies and Privacy Notices.
  • The currency of Data Protection policies and Privacy Notices.
  • The accuracy of Personal Data being stored.
  • The conformity of Data Processor activities.
  • The adequacy of procedures for redressing poor compliance and Personal Data Breaches.

 

4.3Data Protection Principles

Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd has adopted the following principles to govern its collection, use, retention, transfer, disclosure and destruction of Personal Data:

Principle 1: Lawfulness, Fairness and Transparency Personal Data shall be processed lawfully, fairly and in a transparent manner in relation to the Data Subject. This means, Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd must tell the Data Subject what Processing will occur (transparency), the Processing must match the description given to the Data Subject (fairness), and it must be for one of the purposes specified in the applicable Data Protection regulation (lawfulness).

Principle 2: Purpose Limitation

Personal Data shall be collected for specified, explicit and legitimate purposes and not further Processed in a manner that is incompatible with those purposes. This means Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd must specify exactly what the Personal Data collected will be used for and limit the Processing of that Personal Data to only what is necessary to meet the specified purpose.

Principle 3: Data Minimisation

Personal Data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are Processed. This means Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd must not store any Personal Data beyond what is strictly required.

Principle 4: Accuracy

Personal Data shall be accurate and, kept up to date. This means Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd must have in place processes for identifying and addressing out-of-date, incorrect and redundant Personal Data.

Principle 5: Storage Limitation

Personal Data shall be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data is Processed. This means Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd must, wherever possible, store Personal Data in a way that limits or prevents identification of the Data Subject.

Principle 6: Integrity & Confidentiality

Personal Data shall be Processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorised or unlawful Processing, and against accidental loss, destruction or damage. Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd must use appropriate technical and organisational measures to ensure the integrity and confidentiality of Personal Data is maintained at all times.

Principle 7: Accountability

The Data Controller shall be responsible for and be able to demonstrate compliance. This means Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd must demonstrate that the six Data Protection Principles (outlined above) are met for all Personal Data for which it is responsible.

 

4.4 Data Collection

Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd will obtain Personal Data only by lawful and fair means and, where appropriate with the knowledge and Consent of the individual concerned. Where a need exists to request and receive the Consent of an individual prior to the collection, use or disclosure of their Personal Data, Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd is committed to seeking such Consent.

4.5 Data Use

Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd use the Personal Data of its Contacts for the following broad purposes:

  • The general running and business administration of Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd
  • To provide services to Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd customers.
  • The ongoing administration and management of customer services. The use of a Contact’s information should always be considered from their perspective and whether the use will be within their expectations or if they are likely to object. For example, it would clearly be within a Contact’s expectations that their details will be used by Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd to respond to a Contact request for information about the services on offer. However, it will not be within their reasonable expectations that Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd would then provide their details to Third Parties for marketing purposes. Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd will not Process Personal Data unless at least one of the following requirements are met:
  • The Data Subject has given Consent to the Processing of their Personal Data for one or more specific purposes.
  • Processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract.
  • Processing is necessary for compliance with a legal obligation to which the Data Controller is subject.
  • Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person.
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.

4.6 Data Quality 

Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd will adopt all necessary measures to ensure that the Personal Data it collects and Processes is complete and accurate in the first instance, and is updated to reflect the current situation of the Data Subject. Correcting Personal Data known to be incorrect, inaccurate, incomplete, ambiguous, misleading or outdated, even if the Data Subject does not request rectification. Keeping Personal Data only for the period necessary to satisfy the permitted uses or applicable statutory retention period.

4.7 Digital Marketing Contact

Information collected by Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd will not be used for marketing purposes.

4.8 Data Protection

Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd will adopt physical, technical, and organisational measures to ensure the security of Personal Data. This includes the prevention of loss or damage, unauthorised alteration, access or Processing, and other risks to which it may be exposed by virtue of human action or the physical or natural environment. The following security measures will be implemented:

Prevent unauthorised persons from gaining access to data processing systems in which Personal Data are processed.

Prevent persons entitled to use a data processing system from accessing Personal Data beyond their needs and authorisations.

Ensure that Personal Data in the course of electronic transmission during transport cannot be read, copied, modified or removed without authorisation.

Ensure that Personal Data is protected against undesired destruction or loss.

Ensure that Personal Data is not kept longer than necessary.

4.9 Data Subject Requests The Data Protection Officer will establish a system to enable and facilitate the exercise of Data Subject rights related to:

  • Information access.
  • Objection to Processing.
  • Restriction of Processing.
  • Data portability.
  • Data rectification.
  • Data erasure.

If an individual makes a request in relation to any of the above Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd will consider each such request in accordance with all applicable Data Protection laws and regulations. No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be unnecessary or excessive in nature. Data Subjects are entitled to obtain, based upon a request made in writing to the Office of Data Protection and upon successful verification of their identity, the following information about their own Personal Data:

  • The purposes of the collection, Processing, use and storage of their Personal Data
  • The source(s) of the Personal Data, if it was not obtained from the Data Subject
  • The categories of Personal Data stored for the Data Subject.
  • The recipients or categories of recipients to whom the Personal Data has been or may be transmitted, along with the location of those recipients
  • The envisaged period of storage for the Personal Data or the rationale for determining the storage period.

4.10 Data Subject Requests

The right of the Data subject to:

  • object to Processing of their Personal Data.
  • lodge a complaint with the Data Protection Authority.
  • request rectification or erasure of their Personal Data.
  • request restriction of Processing of their Personal Data.

All requests received for access to or rectification of Personal Data must be directed to the Data Protection Officer, who will log each request as it is received. A response to each request will be provided within 30 days of the receipt of the written request from the Data Subject. Appropriate verification must confirm that the requestor is the Data Subject or their authorised legal representative. Data Subjects shall have the right to require Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd to correct or supplement erroneous, misleading, outdated, or incomplete Personal Data. Controlled copy is held in the Policy Management System. Document is uncontrolled if printed. Please check validity before use.

4.11 Law Enforcement Requests & Disclosures

In certain circumstances, it is permitted that Personal Data be shared without the knowledge or Consent of a Data Subject. This is the case where the disclosure of the Personal Data is necessary for any of the following purposes:

The prevention or detection of crime.

The apprehension or prosecution of offenders.

The assessment or collection of a tax or duty.

By the order of a court or by any rule of law.

4.12 Data Protection Training

Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd Employees that have access to Personal Data will have their responsibilities under this policy outlined to them as part of their staff induction training. The training and procedural guidance set forth will consist of, at a minimum, the following elements:

  • Each Employee’s duty to use and permit the use of Personal Data only by authorised persons and for authorised purposes.
  • The need for, and proper use of, the forms and procedures adopted to implement this policy.
  • The correct use of passwords, security tokens and other access mechanisms. The importance of limiting access to Personal Data, such as by using password protected screen savers and logging out when systems are not being attended by an authorised person.
  • Securely storing manual files, print outs and electronic storage media.
  • The need to obtain appropriate authorisation and utilise appropriate safeguards for all transfers of Personal Data outside of the internal network and physical office premises.
  • Proper disposal of Personal Data by using secure shredding facilities.

4.13 Complaints Handling

Data Subjects with a complaint about the Processing of their Personal Data, should put forward the matter in writing to the Data Protection Officer. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case. The Data Protection Officer will inform the Data Subject of the progress and the outcome of the complaint within a reasonable period. If the issue cannot be resolved through consultation between the Data Subject and Data Protection Officer, then the Data Subject may, at their option, seek redress through mediation, binding arbitration, litigation, or via complaint to the Data Protection Authority within the applicable jurisdiction.

4.14 Breach Reporting

Any individual who suspects that a Personal Data Breach has occurred due to the theft or exposure of Personal Data must immediately notify the Data Protection Officer providing a description of what occurred. The Data Protection Officer will investigate all reported incidents to confirm whether or not a Personal Data Breach has occurred. If a Personal Data Breach is confirmed, Data Protection Officer will follow the relevant authorised procedure based on the criticality and quantity of the Personal Data involved.

5. Policy Maintenance

All inquiries about this policy, including requests for exceptions or changes should be directed to the Data Protection Officer

5.1 Publication This policy shall be available to all Hardmoors Ltd, Hardmoors 26.2 Series Ltd and Hardmoors Hardwear Ltd Employees.

5.2 Effective Date This policy is effective as of 20th May 2018

5.3 Revisions

The Data Protection Officer is responsible for the maintenance and accuracy of this policy.

Signed Name: Shirley Steele

Position: Director

Date ……………………20/05/2018………………………….

Renewal date…………………………………………………….