We are The Delivery Group Limited, a company incorporated and registered in England and Wales with company number 07621335, and its subsidiaries Secured Express Limited, a company incorporated and registered in England and Wales with company number 04834987, and CMS Network (London) Limited, a company incorporated and registered in England and Wales with company number 03517482, all of whom have their registered office at Calver Road, Winwick Quay, Warrington, England WA2 8UD (the “Company” or “we” or “us”).
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The Company and personal information: We are committed to lawful, fair and transparent processing of all personal information about our employees, customers, suppliers and other third parties during the course of our business activities. We will always comply with any applicable data protection legislation and we will ensure that collection and use of personal information is carried out in accordance with applicable data protection laws. The main law governing data protection is the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) known as the “GDPR”.
What this policy is: This policy (and any other documents referred to in it, together with any privacy notice displayed on our website) sets out the basis on which we will process any personal information about you or individuals generally – whether it’s information we collect from those individuals or that is provided to us from other sources. This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer or store personal information.
Registration: While the Data Protection Act 1998 requires us to be registered with the
Information Commissioner’s Office, we will remain registered. We will also comply with any successor notification requirements. Please note that, as explained below, we may only be processing your personal data on behalf of another party, such as one of our clients, who will be the data controller in respect of that information.
Controlling and processing information: We are the controller of all personal information used in our business for our own commercial purposes. Sometimes though, we will process personal information on behalf of another data controller – and when this is the case, we will do so only in accordance with the instructions of that data controller and otherwise in accordance with the GDPR. If we are processing on behalf of another data controller, that data controller will provide relevant information to you about how your data is being shared.
Why you should read this policy: It is important that you read this policy, together with any other documents referred to in it, so that you are aware of how any personal information relating to you will be dealt with by us.
We are accountable for demonstrating compliance with the GDPR’s six principles of processing personal information. These provide that personal information we deal with must be:
Personal information: In this policy, when we use the term “personal information” we mean any information relating to an identified or identifiable human being. (An “identifiable natural person” is one who can be identified, directly or indirectly, for example, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, biometric, mental, economic, cultural or social identity of that person).
Sensitive personal information: In this policy, when we use the term “sensitive personal information” we mean special categories of information which are personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying someone, data concerning health or data concerning someone’s sex life or sexual orientation.
We may collect, record, organise, structure, store, adapt, alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destroy the following types of personal information about you:
We do not collect, store or use sensitive personal information.
In the course of our business, we may collect personal information directly from an individual:
We may also collect personal information about individuals from other sources such as:
We will only collect personal information to the extent that it is required for the specific purpose notified to individuals about whom we are collecting it and/or as instructed by any data controller on whose behalf we are acting – and we will keep it only as long as is necessary.
We will only use personal information when the law allows us to do so and relying on a relevant basis for lawful processing in each instance. We will use your personal information in the following circumstances, relying on the basis of processing indicated:
Basis of processing: Where we need to perform a contract we are about to enter into or have entered into with you.
Basis of processing: Where it is necessary for our legitimate interests (or those of a third party, such as a client using our delivery services) and we have undertaken an assessment to determine that processing for those interests (listed below) does not outweigh your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place
Basis of processing: Where we need to comply with a legal or regulatory obligation.
Basis of processing: Where you have consented to the processing.
Other issues about how we use personal information:
As indicated above, we may use your personal information to provide you with information about goods and services which may be of interest to you and we may contact you about these by email, text message, post or telephone call. This is known as direct marketing.
Examples of direct marketing may include:
We will only process personal information for the above purposes as permitted by law, which usually means with your specific consent. You have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.
We may also disclose your information to third parties (including our subsidiaries, our ultimate holding company and its subsidiaries and any marketing agencies for the purpose of direct marketing. Again, we will only do this with your explicit consent and you have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below. Please see “Data Sharing” below for further details.
In this policy, where we have referred to needing your consent for any processing, we will make sure that the consent:
Automated decision-making takes place when an electronic system uses personal information to make a decision relevant to you without human intervention.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
Transfer of personal information outside of the EEA: We may transfer certain personal information that we hold on individuals living in the European Union to a country outside the European Economic Area (“EEA“), provided that one of the following conditions applies:
Subject to the requirements set out above, the personal information we hold may also be processed by individuals operating outside the EEA who work for us or for one of our suppliers. Those individuals may be engaged in, among other things, the fulfilment of contracts with the relevant individual, the processing of payment details and the provision of support services.
Safeguards: If we use a third party data processor to process personal information on our behalf, we will obtain contractual commitments to safeguard the security of the personal information to ensure that the third party only acts on our instructions when using that personal information and that the third party has in place appropriate technical and organisational security measures to safeguard the personal information. Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information outside the EEA.
Why we might share your personal information with third parties: We may share personal information we hold with: (i) any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries; and/or (ii) in the event that we sell or buy any business or assets, or sell the Company, we will disclose your personal data to the prospective seller or buyer of such business or assets. We may also disclose personal information we hold to third parties if we are under a duty to disclose or share an individual’s personal information in order to comply with any legal obligation, or in order to enforce or apply any contract with that individual or other agreements; or to protect our rights, property, or safety of our employees, customers or others. This includes exchanging personal information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We may share personal information with other members in the group as part of our regular reporting activities on company performance, such as providing mailing services to suite the clients expected needs. When appropriate, we will anonymise personal information when used for performance reviewing and reporting activities.
We may also share personal information we hold with selected third parties for the purposes set out below. We do not allow our third-party service providers to use your personal data for their own purposes; we only permit them to process your personal data for specified purposes and in accordance with our instructions.
Third party service providers who may process your personal information: When we use the term “third party”, we mean any entity who is not the Company, including third party service providers, contractors and designated agents and any member of our group. The following third party service providers may process personal information for the following purposes:
We have put in place internal procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will not keep personal information in a form which permits identification of individuals for 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 (or, where we are processing on behalf of another data controller, return their information to them). To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of personal information, the purposes for which we process information and whether we can achieve those purposes through other means, and the applicable legal requirements. Legal requirements to hold transactional data e.g. HMRC tax legislation will determine the ultimate retention period for such types of documentation for example sales invoices, purchase invoices, timesheets etc.
We will only keep personal information for as long as is necessary for the purpose or purposes for which that personal information is processed; and we will let anyone about whom we process data know how long that is or the criteria that go into deciding how long that is.
We may sometimes anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Our website may, from time to time, contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or the security of these websites. Please check the relevant policy before you submit any personal information to these websites.
Under certain circumstances, you have rights under data protection laws in relation to your personal information, as summarised below.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org or contact our Data Processing Manager as detailed below. We aim to respond to all legitimate requests within one month (and if we are only processing the data in question on behalf of another party, the response may actually come from that other party as the relevant data controller). Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive – alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device if you agree. Cookies contain information that is transferred to your computer or device. We use the following cookies2:
1 Most cookies will store personal data and so this data must be treated in the same way as any other personal data. Official guidance is still awaited on the extent to which explicit consent for cookie use will be required but other existing rules will continue to apply, requiring “clear and comprehensive” explanations of what each cookie is doing and allowing an option to opt-out of cookie use. Under GDPR, services should still be offered to data subjects without detriment if they object to any usage of personal data, so where possible the website should be available to those who refuse any or all cookies – and the option to refuse should really be offered as soon as users land on the page and before any cookies are set. 2 To update if any of these types of cookie are not applicable
3 If any cookies are controlled by third parties, or data collected from cookies is shared with third parties, this is unlikely to satisfy the legitimate interests basis of processing and consent is likely to be the only potential basis for processing.
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You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you block cookies you may not be able to access all or parts of our website.
The person responsible for how the Company deals with personal information, our Data Processing Manager, is responsible for ensuring compliance with GDPR and with this policy. The post of Data Processing Manager is held by Mr. James Wilkins, who can be contacted via telephone on 03330 111 999 or via email at email@example.com 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 Processing Manager.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office, so please contact us in the first instance.