GDPR Policy 2018
Rose Narrowboats Ltd
General Data Protection Policy
General Data Protection Regulation (GDPR) 2018 Compliance
Rose Narrowboats Ltd seeks at all times to comply with English law, and to this end has produced a Privacy Notice and accompanying company policy relating to the processing and controlling of such customers’ personal data as it needs to hold to enable business transactions to be completed.
Rose Narrowboats Ltd has to collect and process personal data in order to be able to make hire boat bookings, work boat bookings, contracts for the painting and/repairs of boats, and orders for specially oredered items of chandlery, in a manner which is compliant with relevant legislation. The privacy notice explains what personal data is and what personal data the company collects, why it processes that data and who controls the data. Should a customer wish the company to alter information it holds, or to object or complain about the personal data the company holds, or to make a formal complaint, the Privacy Notice contains information to assist them in doing so, including the name of the person they need to contact and their postal address and e-mail address. The company is responsible for keeping clients’ data safe and secure and for complying with the principles of data contol as laid down in the GDPR
The GDPR define personal data as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Examples of personal data include: name; address; date of birth or any other information from which the individual can be identified
Personal Data Collected and Controlled by Rose Narrowboats Ltd
When a client decides they wish to book a boat with the company, in order to complete hire boat booking contracts, Rose Narrowboats Ltd will need:
- the customer’s contact details (home address, telephone number, e-mail address etc) and payment details
- the company will need to know personal information about all members of the hirer’s party and any information for specific requirements they may have. (The hirer must ask them to give their consent for them to pass on this information to the company)
- for reasons related to safety and insurance the company will need details of any minors in the party
The same sort of data will be required for the booking of a non holiday hire boat (work boat). Contracts for the painting and repair of boats, other repair work, and contracts for the supply of specially ordered chandlery items will require the collection of less data than that necessary for holiday hire boats (see clients’ personal data request and consent form attached).
Sensitive Personal Data
Rose Narrowboats Ltd does not collect sensitive personal data from hirers or members of hirer’s booking party unless it is necessary for it to know additional information to make it possible for the hirer to use the company’s boats, for example if the customer needs to know whether the use of necessary electrically powered medical equipment is possible on the company’s holiday boats.
Personal Data Processed by the Company
Personal data we collect will be processed solely to create a booking for a hire boat. The data will be controlled and processed by Rose Narrowboats Ltd using software designed for the purpose. We are the controller of this data whether you book directly through us or by using our booking agent Waterways Holidays Ltd. We do not engage in direct marketing and we never sell or disclose information about our customers to third parties. The company may have to share personal data with credit/debit card companies and its insurers if necessary in connection with your booking.
Lawful Basis for Processing
Rose Narrowboats’ Ltd’s lawful basis for processing clients’ data is set out below:
- they consent to giving the data to the company
- they enter into a contract with the company for the supply of goods or services
- the data may they provide may be used to protect or comply with the customers’ lawful interests and the company’s own
Managing Clients’ Information Information
Rose Narrowboats Ltd may use operating systems operated by third parties to help meet the business’s needs. If such systems are based outside the United Kingdom they will be fully compliant with relevant privacy laws within the European Economic Area or within those countries which are deemed to have approved privacy protection for such systems.
Updating Clients’ Information
Clients must be asked to ensure that should any of information relating to them or their holiday party change before their holiday with Rose Narrowboats Ltd has been completed, they must so advise the company by contacting its Data Controller (see below).
Time Scales for Data Rentention
As a limited liability company Rose Narrowboats Ltd has to retain certain information for varying lengths of time to comply with English company law. It will keep customers’information for only as long as is necessary for it to comply with this legislation, and will dispose dispose of data thereafter in a safe and secure manner, in accordance with the requirements of the GDPR.
Rights in Relation to Personal Data
People have rights in relation to their personal data. Those rights are summarised below as the right :
- to be informed about the collection and use of their personal data
- to know the company’s reasons for processing that data and its retention periods for that data;
- to know if their data is shared bythe companys, and if so, with whom
- for the information to be presented to the customer in an accessible and easy to understand manner
- to access personal data and supplementary information held by the company
- to have inaccurate personal data rectified or completed if it is incomplete
- to have personal data erased in certain circumstances
- the right to request the restrictiction or suppression of personal data
- the right to data portability, so that they can obtain and re-use their data for their own purposes across different services
- the right to object to their data being processed for certain public interest, profiling, direct marketing and some scientific /historical research and statistics
Alterations, Objections, Complaints Procedure, Data Contoller, Contact Details
Clients’ requests for the alteration of personal information the company holds about them, or any requests for copies of personal information the company holds about them, will be dealt with by the Data Controller, Mr A W Grantham -Jackson, Rose Narrowboats Ltd, Stretton under Fosse, Nr. Rugby, Warwickshire, CV23 0PU. The company will supply information free of charge and within the required timescale. Clients having any objections relating to personal information held should may also addressed them to him, or they may also be referred to the Information Commissioner, whose e-mail address is: https://ico.org/concerns and whose telephone number is 0303 123 1113.
Privacy Notice Updating
This Privacy Notice and its accompanying policies will be reviewed annually (or earlier if cicumstances change) in accordance with Rose Narrowboats Ltd’s annual review and audit of all its operating systems and policies.
Further information relating to GDPR may be found on the website of the Office of the Information Commissioner UK, at https//ico.org.uk.
AKB May 2018