What this covers
This document details your rights and obligations in relation to your personal data that we are handling.
"Personal data" is any information that relates to a living individual who can be identified from that information.
"Processing" is any use that is made of personal data, including collecting, storing, amending, disclosing or destroying it.
"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or political beliefs, trade union membership, health, sex life or sexual orientation and biometric data.
Data Protection principles
The Creamery processes personal data in accordance with the following data protection principles:
· the Creamery processes personal data lawfully, fairly and in a transparent manner.
· the Creamery collects personal data only for specified, explicit and legitimate purposes.
· the Creamery processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of the processing.
· the Creamery keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
· the Creamery retains personal data only for the period necessary for the processing.
· the Creamery adopts appropriate measures to make sure that personal data is secure and is protected against unauthorised or unlawful processing and from accidental loss, destruction or damage.
Your entitlements
Data protection legislation prescribes the way in which the Creamery may collect, retain and handle personal data. The Creamery will comply with the requirements of data protection legislation and all employees and contractors who handle personal data in the course of their work must also comply with it.
The Creamery will inform individuals of the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data about individuals for other reasons.
Where the Creamery processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with the rules relating to special categories of data and criminal records data.
The Creamery will update personal data promptly if an individual advises that their information has changed or is inaccurate.
Access to your personal data [subject access requests]
You have the right to make a subject access request. If you make such a request, the Creamery will tell you:
· whether or not your data is processed and if so why; the categories of personal data concerned and the source of the data if it is not collected from you.
· to whom your data may be disclosed, including any recipients located outside the European Economic Area (EEA) and the safeguards that apply to any such transfers.
· for how long your personal data is stored or how that period is decided.
· your rights to rectification or erasure of data, or to restrict or object to processing.
· your right to complain to the Information Commissioner if you think the Creamery has failed to comply with your data protection rights; and
· whether or not the Creamery carries out any automated decision-making and the logic involved in such decision-making.
The Creamery will also provide you with a copy of the personal data under going processing. This will normally be in electronic form if you have made the request electronically, unless you request otherwise.
If you want additional copies, the Creamery will charge a fee, which will be based on the administrative cost of providing the additional copies.
Other rights
You have a number of other rights in relation to your personal data. You can require the Creamery to:
· rectify inaccurate data.
· stop processing or erase data if your interests override the Creamery's legitimate grounds for processing data (where the Creamery relies on its legitimate interests as a lawful basis for processing data).
· stop processing or erase data if it is unlawful; and
· stop processing data for a period if it is inaccurate or if there is a dispute about whether or not your interests override the Creamery's legitimate interests for processing the data.
Procedure
The Creamery keeps a record of its processing activities in respect of personal data in accordance with the requirements of data protection legislation.
Personal data may be collected by the Creamery for the purposes of:
· recruitment, promotion, training, redeployment and/or career development, such as references, CVs and appraisal documents.
· recording of communication with customers and suppliers and their representatives.
· the marketing, selling and purchasing of goods with customers and suppliers.
· financial information for payment purposes.
· monitorand compliance with security and health and safety.
· compliance with legislation.
How we use special categories
"Special categories" data require higher levels of protection. We need to have further justification for collecting, storing, and processing these types of personal data. We may process special categories data in the following circumstances:
· where it is needed to assess access to the Creamery premises (on health grounds).
· in limited circumstances, with your explicit written consent.
· where we need to carry out our legal obligations.
Accuracy of personal data
The Creamery will review personal data regularly to ensure that it is accurate, relevant and upto date.
Security of personal data
The Creamery will ensure that personal data is not processed unlawfully, lost or damaged.
Data breaches
The Creamery will record all data breaches regardless of their effect.
If we discover that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, we will report it to the Information Commissioner within 72 hours of discovery.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, we will tell affected individuals that there has been a breach and provide them with information about the likely consequences of the breach and the mitigation measures we have taken.
Access to personal data ["subject access requests"]
To make a subject access request, you should send your request to the Creamery. In some cases, the Creamery may need to ask for proof of identification before the request can be processed. We will inform you if we need to verify your identity and the documents we require.
We will normally respond to a request within one month from the date we receive it. In some cases, such as where the Creamery processes large amounts of the individual's data, we may respond within three months of the date the request is received. We will write to the individual within one month of receiving the original request to tell them if this is the case.
If a subject access request is manifestly unfounded or excessive, the Creamery is not obliged to comply with it. Alternatively, we can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which we have already responded. If you submit a request that is unfounded or excessive, we will notify you that this is the case and whether we will respond to it.
If you have any questions about the Creamery’s collection, storage and use of personal data then please contact us:
Fife Creamery Ltd,
Randolph Place,
Randolph Industrial Estate,
Kirkcaldy,
KY1 2YX
What this covers
This document details your rights and obligations in relation to your personal data that we are handling.
"Personal data" is any information that relates to a living individual who can be identified from that information.
"Processing" is any use that is made of personal data, including collecting, storing, amending, disclosing or destroying it.
"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or political beliefs, trade union membership, health, sex life or sexual orientation and biometric data.
Data Protection principles
The Creamery processes personal data in accordance with the following data protection principles:
· the Creamery processes personal data lawfully, fairly and in a transparent manner.
· the Creamery collects personal data only for specified, explicit and legitimate purposes.
· the Creamery processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of the processing.
· the Creamery keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
· the Creamery retains personal data only for the period necessary for the processing.
· the Creamery adopts appropriate measures to make sure that personal data is secure and is protected against unauthorised or unlawful processing and from accidental loss, destruction or damage.
Your entitlements
Data protection legislation prescribes the way in which the Creamery may collect, retain and handle personal data. The Creamery will comply with the requirements of data protection legislation and all employees and contractors who handle personal data in the course of their work must also comply with it.
The Creamery will inform individuals of the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data about individuals for other reasons.
Where the Creamery processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with the rules relating to special categories of data and criminal records data.
The Creamery will update personal data promptly if an individual advises that their information has changed or is inaccurate.
Access to your personal data [subject access requests]
You have the right to make a subject access request. If you make such a request, the Creamery will tell you:
· whether or not your data is processed and if so why; the categories of personal data concerned and the source of the data if it is not collected from you.
· to whom your data may be disclosed, including any recipients located outside the European Economic Area (EEA) and the safeguards that apply to any such transfers.
· for how long your personal data is stored or how that period is decided.
· your rights to rectification or erasure of data, or to restrict or object to processing.
· your right to complain to the Information Commissioner if you think the Creamery has failed to comply with your data protection rights; and
· whether or not the Creamery carries out any automated decision-making and the logic involved in such decision-making.
The Creamery will also provide you with a copy of the personal data under going processing. This will normally be in electronic form if you have made the request electronically, unless you request otherwise.
If you want additional copies, the Creamery will charge a fee, which will be based on the administrative cost of providing the additional copies.
Other rights
You have a number of other rights in relation to your personal data. You can require the Creamery to:
· rectify inaccurate data.
· stop processing or erase data if your interests override the Creamery's legitimate grounds for processing data (where the Creamery relies on its legitimate interests as a lawful basis for processing data).
· stop processing or erase data if it is unlawful; and
· stop processing data for a period if it is inaccurate or if there is a dispute about whether or not your interests override the Creamery's legitimate interests for processing the data.
Procedure
The Creamery keeps a record of its processing activities in respect of personal data in accordance with the requirements of data protection legislation.
Personal data may be collected by the Creamery for the purposes of:
· recruitment, promotion, training, redeployment and/or career development, such as references, CVs and appraisal documents.
· recording of communication with customers and suppliers and their representatives.
· the marketing, selling and purchasing of goods with customers and suppliers.
· financial information for payment purposes.
· monitorand compliance with security and health and safety.
· compliance with legislation.
How we use special categories
"Special categories" data require higher levels of protection. We need to have further justification for collecting, storing, and processing these types of personal data. We may process special categories data in the following circumstances:
· where it is needed to assess access to the Creamery premises (on health grounds).
· in limited circumstances, with your explicit written consent.
· where we need to carry out our legal obligations.
Accuracy of personal data
The Creamery will review personal data regularly to ensure that it is accurate, relevant and upto date.
Security of personal data
The Creamery will ensure that personal data is not processed unlawfully, lost or damaged.
Data breaches
The Creamery will record all data breaches regardless of their effect.
If we discover that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, we will report it to the Information Commissioner within 72 hours of discovery.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, we will tell affected individuals that there has been a breach and provide them with information about the likely consequences of the breach and the mitigation measures we have taken.
Access to personal data ["subject access requests"]
To make a subject access request, you should send your request to the Creamery. In some cases, the Creamery may need to ask for proof of identification before the request can be processed. We will inform you if we need to verify your identity and the documents we require.
We will normally respond to a request within one month from the date we receive it. In some cases, such as where the Creamery processes large amounts of the individual's data, we may respond within three months of the date the request is received. We will write to the individual within one month of receiving the original request to tell them if this is the case.
If a subject access request is manifestly unfounded or excessive, the Creamery is not obliged to comply with it. Alternatively, we can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which we have already responded. If you submit a request that is unfounded or excessive, we will notify you that this is the case and whether we will respond to it.
If you have any questions about the Creamery’s collection, storage and use of personal data then please contact us:
Fife Creamery Ltd,
Randolph Place,
Randolph Industrial Estate,
Kirkcaldy,
KY1 2YX
