1. Policy statement

1.1 Everyone has rights with regard to the way in which their personal data in handled.

During the course of our activities we will collect, store and process personal data

about our customers, suppliers and other third parties, and we recognise that the

correct and lawful treatment of this data will maintain confidence in the organisation

and will provide for successful business operations.

1.2 Data users are obliged to comply with this policy when processing personal data

on our behalf. Any breach of this policy may result in disciplinary action.

2. About this policy

2.1 The types of personal data that the Company may be required to handle include

information about current, past and prospective suppliers, customers, and others

that we communicate with. The personal data, which may be held on paper or on a

computer or other media, is subject to certain legal safeguards specified in the

Data Protection Act 1998 (the Act) and other regulations.

2.2 This policy and any other documents referred to in it sets out the basis on which

we will process any personal data we collect from data subjects, or that is provided

to us by data subjects or other sources.

2.3 This policy does not form part of any employee’s contract of employment and may

be amended at any time.

2.4 This policy sets out rules on data protection and the legal conditions that must be

satisfied when we obtain, handle, process, transfer and store personal data.

2.5 The Company, normally through the Data Protection Compliance Manager is

responsible for ensuring compliance with the Act and with this policy. Any

questions about the operation of this policy or any concerns that the policy has not

been followed should be referred in the first instance to the Data Protection

Compliance Manager or to a senior Manager.

3.     Definition of data protection terms

3.1 Data is information which is stored electronically, on a computer, or in certain

paper-based filing systems.

Registered Office: Chy Nyverow, Newham Road, TRURO, Cwll  TR1 2DP     No. 04888323

3.2 Data subjects for the purpose of this policy include all living individuals about

whom we holds personal data. A data subject need not be a UK national or

resident. All data subjects have legal rights in relation to their personal information.

3.3 Personal data means data relating to a living individual who can be identified from

that data (or from that data and other information in our possession). Personal data

can be factual (for example, a name, address or date of birth) or it can be an

opinion about that person, their actions and behaviour.

3.4 Data controllers are the people who or organisations which determine the

purposes for which, and the manner in which, any personal data is processed.

They are responsible for establishing practices and policies in line with the Act. We

are the data controller of all personal data used in our business for our own

commercial purposes.

3.5 Data users are those of our employees whose work involves processing personal

data. Data users must protect the data they handle in accordance with this data

protection policy and any applicable data security procedures at all times.

3.6 Data processors include any person or organisation that is not a data user that

processes personal data on our behalf and on our instructions. Employees of data

controllers are excluded from this definition but it could include suppliers which

handle personal data on the Company’s behalf.

3.7 Processing is any activity that involves use of the data. It includes obtaining,

recording or holding the data, or carrying out any operation or set of operations on

the data including organising, amending, retrieving, using, disclosing, erasing or

destroying it. Processing also includes transferring personal data to third parties.

3.8 Sensitive personal data includes information about a person’s racial or ethnic

origin, political opinions, religious or similar beliefs, trade union membership,

physical or mental health or condition or sexual life, or about the commission of, or

proceedings for, any offence committed or alleged to have been committed by that

person, the disposal of such proceedings or the sentence of any court in such

proceedings. Sensitive personal data can only be processed under strict

conditions, including a condition requiring the express permission of the person


4. Data protection principles

Anyone processing personal data must comply with the eight enforceable principles of

good practice. These provide that personal data must be:

Processed fairly and lawfully.

(a) Processed for limited purposes and in an appropriate way.

(b) Adequate, relevant and not excessive for the purpose.

(c) Accurate.

Registered Office: Chy Nyverow, Newham Road, TRURO, Cwll  TR1 2DP     No. 04888323

(d) Not kept longer than necessary for the purpose.

(e) Processed in line with data subjects’ rights.

(f) Secure.

(g) Not transferred to people or organisations situated in countries without adequate


5. Fair and lawful processing

5.1 The Act is not intended to prevent the processing of personal data, but to ensure

that it is done fairly and without adversely affecting the rights of the data subject.

5.2 For personal data to be processed lawfully, they must be processed on the basis of

one of the legal grounds set out in the Act. These include, among other things, the

data subject’s consent to the processing, or that the processing is necessary for

the performance of a contract with the data subject, for the compliance with a legal

obligation to which the data controller is subject, or for the legitimate interest of the

data controller or the party to whom the data is disclosed. When sensitive personal

data is being processed, additional conditions must be met. When processing

personal data as data controllers in the course of our business, we will ensure that

those requirements are met.

6. Processing for limited purposes

6.1 In the course of our business, we may collect and process the personal data. This

may include data we receive directly from a data subject (for example, by

completing forms or by corresponding with us by mail, phone, email or otherwise)

and data we receive from other sources (including, for example, business partners,

sub-contractors in technical, payment and delivery services, credit reference

agencies and others).

6.2 We will only process personal data for the specific purposes set out in this policy or

for any other purposes specifically permitted by the Act. We will notify those

purposes to the data subject when we first collect the data or as soon as possible


7. Notifying data subjects

7.1 If we collect personal data directly from data subjects, we will inform them about:

(a) The purpose or purposes for which we intend to process that personal data.

(b) The types of third parties, if any, with which we will share or to which we will

disclose that personal data.

(c) The means, if any, with which data subjects can limit our use and disclosure of

their personal data.

Registered Office: Chy Nyverow, Newham Road, TRURO, Cwll  TR1 2DP     No. 04888323

7.2 If we receive personal data about a data subject from other sources, we will

provide the data subject with this information as soon as possible thereafter.

7.3 We will also inform data subjects whose personal data we process that we are the

data controller with regard to that data, and who the Data Protection Compliance

Manager is.

8. Adequate, relevant and non-excessive processing

We will only collect personal data to the extent that it is required for the specific

purpose notified to the data subject.

9. Accurate data

We will ensure that personal data we hold is accurate and kept up to date. We will

check the accuracy of any personal data at the point of collection and at regular

intervals afterwards. We will take all reasonable steps to destroy or amend

inaccurate or out-of-date data.

10. Timely processing

We will not keep personal data longer than is necessary for the purpose or

purposes for which they were collected. We will take all reasonable steps to

destroy, or erase from our systems, all data which is no longer required.

11. Processing in line with data subject’s rights

We will process all personal data in line with data subjects’ rights, in particular their

right to:

(a) Request access to any data held about them by a data controller (see also clause


(b) Prevent the processing of their data for direct-marketing purposes.

(c) Ask to have inaccurate data amended (see also clause 9.).

(d) Prevent processing that is likely to cause damage or distress to themselves or

anyone else.

12. Data security

12.1 We will process all personal data we hold in accordance with our Data Security

Policy OR take appropriate security measures against unlawful or unauthorised

processing of personal data, and against the accidental loss of, or damage to,

personal data.

12.2 We will put in place procedures and technologies to maintain the security of all

personal data from the point of collection to the point of destruction. Personal data 

Registered Office: Chy Nyverow, Newham Road, TRURO, Cwll  TR1 2DP     No. 04888323

will only be transferred to a data processor if he agrees to comply with those

procedures and policies, or if he puts in place adequate measures himself.

12.3 We will maintain data security by protecting the confidentiality, integrity and

availability of the personal data, defined as follows:

(a) Confidentiality means that only people who are authorised to use the data can

access it.

(b) Integrity means that personal data should be accurate and suitable for the

purpose for which it is processed. 

(c) Availability means that authorised users should be able to access the data if

they need it for authorised purposes. Personal data should therefore be stored on

the Company’s central computer system instead of individual PCs.

12.4 Security procedures include:

(a) Entry controls. Any stranger seen in entry-controlled areas should be reported.

(b) Secure lockable desks and cupboards. Desks and cupboards should be kept

locked if they hold confidential information of any kind. (Personal information is

always considered confidential.) 

(c) Methods of disposal. Paper documents should be shredded. Digital storage

devices should be physically destroyed when they are no longer required. 

(d) Equipment. Data users must ensure that individual monitors do not show

confidential information to passers-by and that they log off from their PC when it

is left unattended.

13. Transferring personal data to a country outside the EEA

13.1 We may transfer any personal data we hold to a country outside the European

Economic Area (“EEA”), provided that one of the following conditions applies:

(a) The country to which the personal data are transferred ensures an adequate level

of protection for the data subjects’ rights and freedoms.

(b) The data subject has given his consent.

(c) The transfer is necessary for one of the reasons set out in the Act, including the

performance of a contract between us and the data subject, or to protect the vital

interests of the data subject.

(d) The transfer is legally required on important public interest grounds or for the

establishment, exercise or defence of legal claims.

(e) The transfer is authorised by the relevant data protection authority where we

have adduced adequate safeguards with respect to the protection of the data 

Registered Office: Chy Nyverow, Newham Road, TRURO, Cwll  TR1 2DP     No. 04888323

subjects’ privacy, their fundamental rights and freedoms, and the exercise of their


13.2 Subject to the requirements in clause  above, personal data we hold may also be

processed by staff operating outside the EEA who work for us or for one of our

suppliers. That staff maybe engaged in, among other things, the fulfilment of

contracts with the data subject, the processing of payment details and the

provision of support services. 

14. Disclosure and sharing of personal information

14.1 We may share personal data we hold with any member of our group, which means

our subsidiaries, our ultimate holding company and its subsidiaries, as defined in

section 1159 of the UK Companies Act 2006.

14.2 We may also disclose personal data we hold to third parties:

(a) In the event that we sell or buy any business or assets, in which case we may

disclose personal data we hold to the prospective seller or buyer of such

business or assets.

(b) If we or substantially all of our assets are acquired by a third party, in which case

personal data we hold will be one of the transferred assets.

14.3 If we are under a duty to disclose or share a data subject’s personal data in order

to comply with any legal obligation, or in order to enforce or apply any contract

with the data subject or other agreements; or to protect our rights, property, or

safety of our employees, customers, or others. This includes exchanging

information with other companies and organisations for the purposes of fraud

protection and credit risk reduction.

14.4 We may also share personal data we hold with selected third parties for the

purposes set out in this policy.

15. Dealing with subject access requests

15.1 Data subjects must make a formal request for information we hold about them.

This must be made in writing. Employees who receive a written request should

forward it to [their line manager OR the Data Protection Compliance Manager]


15.2 When receiving telephone enquiries, we will only disclose personal data we hold

on our systems if the following conditions are met:

(a) We will check the caller’s identity to make sure that information is only given to a

person who is entitled to it.

(b) We will suggest that the caller put their request in writing if we are not sure about

the caller’s identity and where their identity cannot be checked.

Registered Office: Chy Nyverow, Newham Road, TRURO, Cwll  TR1 2DP     No. 04888323

15.3 Our employees will refer a request to their line manager [or the Data Protection

Compliance Manager] for assistance in difficult situations. Employees should not

be bullied into disclosing personal information.

16. Changes to this policy

We reserve the right to change this policy at any time. Where appropriate, we will notify

data subjects of those changes by mail or email.


Dated 5 April 2021

Registered Office: Chy Nyverow, Newham Road, TRURO, Cwll  TR1 2DP     No. 04888323