Watts of Lydney Group Limited is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).
Watts of Lydney Group Limited is a “data controller”. This means that we are required under data protection legislation to notify you of the information contained in this privacy notice.
You should read this notice so that you are aware of how and why we are using such information.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
The kind of information we hold about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The personal data we collect will depend on the relationship we have we have with you and why we interact with you or the organisation that you represent.
We may collect, store, and use the following categories of personal information about you:
How is your personal information collected?
We collect personal information from you directly. We may sometimes collect additional information from publicly available resources (e.g. Companies House, H M Land Registry etc), third parties in- cluding former employers, credit reference agencies, through our website, and via our email and IT systems.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
Situations in which we will use your personal information
We need all the categories of information that we collect primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your person- al information to pursue legitimate interests of our own or those of third parties, provided your inter- ests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
Some of the above grounds for processing will overlap and there may be several grounds which jus- tify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a product or service), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our or your workers).
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Promotional Communications Including Newsletters
We may use your personal data to send you updates by email, text message, telephone or post:
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is neces- sary to administer the working relationship with you or where we have another legitimate interest in doing so.
Which third parties may we share information with?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Transferring information outside the EU
[We will transfer the personal information we collect about you to the following [country OR coun- tries] outside the EU [LIST] in order to perform our contract with you. There [is OR is not] an ade- quacy decision by the European Commission in respect of [that OR those] [country OR countries]. This means that the [country OR countries] to which we transfer your data are [deemed OR not deemed] to provide an adequate level of protection for your personal information.
However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measure[s] to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection: [SPECIFY MEASURE, FOR EXAMPLE, BINDING CORPORATE RULES]. If you require further information about [this OR these] protective measure[s], [you can request it from [POSITION] OR it is available [ON THE INTRANET/PROVIDE LINK HERE].]
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from be- ing accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we col- lected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
When it is no longer necessary to keep your data we will destroy it.
Transferring Data Outside the EEA
To deliver services to you it may be necessary to share your personal data outside the European Economic Area, e.g..
These transfers are subject to special rules under European and UK data protection law. We will ensure that any such transfer complies with GDPR and all data is secure. We use data transfer clauses that have been approved by the European Commission.
Rights of access, correction, erasure, and restriction
You have the following rights that are available free of charge.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact firstname.lastname@example.org.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Data protection officer
You may contact our GDPR team on email@example.com at any time. 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.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.