UK GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
Tin Lid Protection (TLP) Ltd. ("We") are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the UK General Data Protection Regulation (the “UK GDPR”).
- Data controller: A controller determines the purposes and means of processing personal data.
- Data processor: A processor is responsible for processing personal data on behalf of a controller.
- Data subject: Natural person.
- Data protection legislation: Means the data protection legislation enforce in the UK from time to time and includes the Data Protection 2018 (as amended) and the UK General Data Protection Regulation (UK GDPR).
Categories of data: Personal data and special categories of personal data.
- Personal data: The UK GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of UK GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
- Special categories personal data: The UK GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of UK GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
- Processing: Means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as 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.
- Third party: Means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Who are we?
Tin Lid Protection (TLP) Ltd. is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: email@example.com 01380 609 383. For all data matters contact our Data Protection Officer: Chris Flannagan firstname.lastname@example.org .
The purpose(s) of processing your personal data.
We use your personal data for the following purposes:
- To fulfil contractual obligations, either though employment or purchase of services.
- Complying with legal obligations.
- To protect your interest or that of another natural person.
- Where processing is necessary for the purposes of the legitimate interests pursued by the controller, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
The categories of personal data concerned.
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
We process information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (such as name or home address).
Special categories personal data.
We use special categories of personal data to uniquely identify an individual, such as health data, ethnic origin, for the purposes of employment monitoring.
What is our legal basis for processing your personal data?
For personal data we are governed by Article 6 of the UK GDPR.
Our lawful basis for processing your general personal data may include your consent; to fulfil a contractual obligation; to comply with necessary legal obligation; purposes necessary to protect the vital interest of a data subject or another person; for performance of a task carried our in the public interest in the exercise of official authority; and where it is necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject.
Our lawful basis for processing your special categories of data is where we have your explicit consent; where it is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement; where we are required to protect the vital interests of a data subject or another individual where the data subject is physically or legally incapable of giving consent; the processing is necessary for the establishment, exercise or defence of legal claims or where courts are acting in their judicial capacity; where the processing is necessary for the reasons of substantial public interest on the basis of the data protection legislation; where processing is necessary for reasons of preventative or occupational medicine, for assessing the working capacity of an employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of data protection legislation or a contract with a health professional; if processing is necessary for the reasons of public interest in the area of public health; or for processing necessary for archiving purposes in the public interest
More information on lawful processing can be found on the ICO website.
Sharing your personal data.
Your personal data will be treated as strictly confidential, and will be shared only with those who have a legitimate reason to access, process, or manage your data.
How long do we keep your personal data?
We keep your data for no longer than is reasonably required, and comply with Article 5 (1) of the GDPR (UK).
Providing us with your personal data.
You are under no statutory or contractual requirement or obligation to provide us with your personal data.
Failure to provide personal data may result in Tin Lid Protection (TLP) Ltd. fulfilling our contractual obligation with you.
Your rights and your personal data.
Unless subject to an exemption under the UK GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you.
- The right to request that we correct any personal data if it is found to be inaccurate or out of date.
- The right to request your personal data is erased where it is no longer necessary to retain such data
- The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data.
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means).
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
- The right to object to the processing of personal data, where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); (direct marketing and processing for the purposes of scientific/historical research and statistics).
Transfer of Data Abroad.
We do not transfer data outside of the UK.
Automated Decision Making.
We do not use any form of automated decision making in our business.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
How to make a complaint.
To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Officer: Chris Flannagan email@example.com .
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.