General Data Protection Regulations
Adrian Clewes and Nicola Lessiter are the Data Controller Officers.
If you have any questions about your personal data which are not answered by this Policy, please contact either Adrian or Nicola.
How We Collect Your Personal Data
Information provided by you
We collect your personal data to give you the best possible experience as a customer of our products. In general, we collect information from you when you interact with us to request a quote or availability check, open an account, visit our website, or contact us with an enquiry or complaint. This covers all channels of communication with us, including over the telephone (all calls are recorded), email, fax, postal service, website, social media and in person.
We’ll collect the following information from you when you request a quote or availability check:
- Your name and position;
- Business name;
- Contact address;
- Delivery address;
- Email address; and
- Telephone number.
When you open an account, in addition to the above, we’ll also collect:
- Name and contact details of individuals authorised to access your account;
- Bank account or payment details; and
- Name and contact details of person responsible for payments.
Should your circumstances change, we may also ask for the following to allow us to service your account:
- Your new address; and
- Banking details, should you decide you would like to set up a direct debit with us, or change bank.
We will also obtain or request the following information if you contact us with an enquiry or complaint:
- Any information that you disclose to us as part of your enquiry or complaint.
Necessary information to resolve your complaint, which could include:
- Proof of Delivery documentation;
- Invoices; and
- Legal documentation.
Information Collected From Other Sources
We may obtain your personal data when you interact with us through third parties, such as third party suppliers.
Credit reference agencies:
- When you open an account with us, your credit score will be provided to us by third party credit reference agencies.
How We Use Your Personal Data
We’ll use your personal data for the purposes outlined below:
- To fulfill our contractual agreement to provide you with our products;
- Where requested by you, to provide you with a quotation for any of our products;
- To deliver our products to you according to our contractual agreement;
- To obtain proof of delivery and thus validate invoices;
- To collect customer payments and manage payment plans;
- To contact you with important information about your account, including bills and statements;
- To comply with our legal obligations, and for the establishment, exercise or defence of legal claims;
- To meet our data protection obligations to verify your identity, before we provide you with information relating to your account;
- To resolve any disputes relating to our service of supplying product;
- For the detection and prevention of crime, including any investigations into potential fraudulent activity, such as energy theft; and
- To respond to requests for information from the police and government bodies, to support in criminal investigations.
Where we have legitimate business interests:
- To respond to customer enquiries and complaints;
- To manage payment schedules, credit levels and debt collection;
- To understand customer consumer patterns, so that we can provide you with products that are best suited to your requirements;
- For management information (MI) reporting purposes, to help us continually improve our offering to our customers; and
- To assess the financial vulnerability of our customers.
Where we have your consent:
- To provide you with information about products that we think you’d benefit from in accordance with your consumer pattern and preferences.
- If you are an existing customer, subject to your purchasing preferences, or where you have otherwise expressly consented, we’ll send you relevant information about products that we think you’d benefit from. This could include updates about product availability and pricing;
- We’ll never sell your data to third parties for marketing purposes;
- This information could be sent to you via text, telephone, fax, email or post; and
- You can opt out or update your preferences at any time by contacting Adrian Clewes or Nicola Lessiter.
We’ll perform automated processing in the form of a credit check before we open an account for you. We use credit reference agencies to confirm the following:
- That you operate from the address given;
- The previous addresses you may have occupied; and
- Your credit score. This is calculated by credit reference agencies based on information including (but not limited to) your financial accounts, credit applications and insolvency related events.
Sharing Your Personal Data
Your personal data may also be shared with the following categories of third parties:
- Debt collection agencies, to help us recover any outstanding debt;
- Credit reference agencies, to enable us to perform a credit check prior to entering into contract with you;
- Payment providers, to enable you to make online payments for our products;
- Industry regulators, legal and tax services, to help us comply with our legal and regulatory obligations;
- The police, should we be required to provide any information to support an investigation;
- Dispute and complaints services, should we need to resolve a complaint with you;
- IT service providers, to enable us to manage and host our IT platforms; and
- Social media platforms and management tools, to enable us to respond to any communications with you via our social media channels.
Sharing Your Personal Data (cont.)
We will also disclose your personal data to third parties:
(a) where it is in our legitimate interests to do so to run, grow and develop our business:
i. if we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets; and
ii. if we are under a duty to disclose or share your personal data to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity.
(b) to enforce our contract with you, to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
(c) to protect the rights, property or safety of our employees, customers, suppliers or other persons.
Some of the companies with whom we share your data [including our group companies] may use your data in countries which are outside of the European Economic Area. Please see the section below entitled “Where is my personal data stored?” for more detail on this aspect.
Same as expressly detailed above, we will never share, sell or rent any of your personal data to any third party without notifying you and/or obtaining your consent. Where you have given your consent for us to use your personal data in a particular way, but later change your mind, you should contact us and we will stop doing so. You can do so by contacting Adrian Clewes or Nicola Lessiter.
Where Is My Personal Data Stored?
Paper records containing personal information are stored in locked filing cabinets.
Electronic records of personal information are held in the server. Access is secured by antivirus and security systems. Access by user unique password.
Freshview Foods Limited have implemented appropriate technical and organisational measures to protect the confidentiality of the personal data that you entrust us with. We update and test our physical, logical and procedural security controls on an ongoing basis. These include limiting access to your personal data to those who need it and training our employees about the importance of maintaining the privacy and security of your personal data.
How long do we keep this information?
- To comply with the statutory retention periods for accounting records, as set by the Companies Act and HM Revenue & Customs (HMRC).
Where our retention periods are not governed by legislation, our retention policy is based on commercial justifications, which have been set in accordance with the principle of retaining personal data for no longer than is necessary for the purposes for which it is processed. These include:
- To enable us to provide you with our products;
- To allow us to resolve any disputes or complaints; and
- For the detection and prevention of fraud.
Data Subject Rights
The following section sets out your rights in relation to your personal data. This includes your rights under the Data Protection Act, in addition to the enhanced rights that you will be entitled to post 25th May 2018, following the coming into force of the GDPR.
If you would like to exercise any of your data subject rights, please contact Adrian Clewes or Nicola Lessiter.
You have the following rights and choices in relation to your personal data:
Certain personal data may be exempt from such requests in certain circumstances. If an exemption applies, we will tell you this when responding to your request. We may request that you provide us with information necessary to confirm your identity before responding to any request you make.
2. You have the right to ensure that any information we hold about you is accurate and kept up to date. Please let us know if you would like to update any inaccurate or incomplete records.
You are also entitled to the following additional rights under the GDPR. These rights will become effective after 25th May 2018.
3. You have the right to request that we erase your personal data on the following grounds:
- Your personal data is no longer necessary in relation to the purpose for which it was collected or processed;
- If the processing is based on consent, you choose to withdraw your consent and there is no other legal ground for processing;
- You object to processing, and there are no overriding legitimate grounds to continue the processing;
- Your personal data has been processed unlawfully; and
- Your personal data must be erased for compliance with a legal obligation.
4. You have the right to request the restriction of processing of your personal data under specific conditions, unless we have a lawful reason to continue, such as for the establishment, exercise or defence of legal claims.
5. You have the right to request a copy of personal data you have provided to us in a structured, commonly used and machine readable format, so that you can transmit this to another organisation. Where technically feasible you can also request that we transmit this data to another organisation.
6. You have the right to object to processing which is based on:
- Legitimate interests;
- Tasks carried out in the public interest; and
- Direct marketing.
7. You have the right not to be subject to any decisions made based solely on automated processing, including profiling, which produces legal effects or significantly affects you. Where such decisions are made, you have the right to:
- Obtain human intervention;
- Express your point of view; and
- Obtain an explanation of the decision and challenge it.
If you would like to make a complaint, please contact Adrian Clewes or Nicola Lessiter on 01782 717806.
You also have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office.