The purpose of this document, is to verify “Equine Clearance’s” commitment to the regulations of the General Data Protection Regulation, coming into effect 25.5.2018. As an organisation, Equine Clearance is transparent in how data is obtained and used; whilst meeting all data protection obligations. This policy outlines individual rights and obligations, in relation to personal data. This policy applies to the personal data of customers, referred to as HR-related personal data.
Equine Clearance has appointed Liberty Rimmer as its data protection officer. Her role, amongst others, is to be proficient in informing and advising data protection obligations.
To contact Liberty, please use the contact email provided below with any questions or queries you may have.
Furthermore, if any additional information is required in relation to this policy. Please direct these to the data protection officer.
"Personal data" is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
Data protection principles:
Equine Clearance processes HR-related personal data in accordance with the following data protection principles:
- Equine Clearance processes personal data lawfully, fairly and in a transparent manner.
- Equine Clearance collects personal data only for specified, explicit and legitimate purposes.
- Equine Clearance processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
- Equine Clearance keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
- Equine Clearance keeps personal data only for the period necessary for processing.
- Equine Clearance adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.
Equine Clearance is committed to informing individuals as to why their personal data has been processed. Furthermore, how the data is handled and the legal basis for processing in its privacy notices. It is imperative to understand; personal data will not be processed for any other reasons.
Equine Clearance, will imminently update HR-related personal data if informed by an individual that their information has changed or inaccurate.
Personal Data obtained during customer activity, is stored in the individuals personnel file via an electronic format; as well as HR systems. Only the Data protection officer has access to this sensitive information, under an encrypted document.
To ensure security and compliance of the General Data Protection Act, Equine Clearance will keep a record of processing activities to ensure the upmost proficiency. As well as respecting HR-related personal data, in accordance with the requirements of GDPR.
As a data subject, individuals have a number of rights in relation to their personal data.
Subject access requests:
Individuals have the right to make a subject access request. If an individual makes a subject access request, Equine Clearance will tell him/her:
- Whether or not his/her 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 the individual;
- To whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
- For how long his/her personal data is stored (or how that period is decided);
- His/her rights to rectification or erasure of data, or to restrict or object to processing;
- His/her right to complain to the Information Commissioner if he/she thinks Equine Clearance has failed to comply with his/her data protection rights; and
- Whether or not Equine Clearance carries out automated decision-making and the logic involved in any such decision-making.
- However, before making this decision. Please make sure you have contacted Equine Clearance first.
Equine Clearance will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically unless he/she agrees otherwise.
To make a subject access request, the individual should send the request to firstname.lastname@example.org In some cases, Equine Clearance may need to ask for proof of identification before the request can be processed. Equine Clearance will inform the individual if it needs to verify his/her identity and the documents it requires.
Equine Clearance will normally respond to a request within a period of one week from the date it is received. In some cases, such as where Equine Clearance processes large amounts of the individual's data, it may respond within one month of the date the request is received. Equine Clearance will write to the individual within one month of receiving the original request to tell him/her if this is the case.
If a subject access request is manifestly unfounded or excessive, Equine Clearance is not obliged to comply with it. Alternatively, Equine Clearance 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 Equine Clearance has already responded. If an individual submits a request that is unfounded or excessive, Equine Clearance will notify him/her that this is the case and whether or not it will respond to it.
Individuals have a number of other rights in relation to their personal data. They can require Equine Clearance to:
- rectify inaccurate data;
- stop processing or erase data that is no longer necessary for the purposes of processing;
- stop processing or erase data if the individual's interests override Equine Clearance's legitimate grounds for processing data
- stop processing or erase data if processing is unlawful; and
- stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual's interests override Equine Clearance 's legitimate grounds for processing data.
To ask Equine Clearance to take any of these steps, the individual should send the request to email@example.com
Equine Clearance takes the security of HR-related personal data seriously. Equine Clearance has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.
What we collect:
We collect the following information:
- Contact information including email address and phone number
- Demographic information such as address
- Other information relevant to customer surveys and/or offers
What we do with the information we gather?
We require this information to understand your needs and provide you with a better service, and for the following reasons:
- Internal record keeping.
- We use the information to get your purchased item to you.
- We send promotional emails if ticked about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Cookies allow web applications to respond to you as an individual. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
Equine Clearance engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and Equine Clearance measures to ensure the security of data.
- Shipping such as Royal Mail, DPD, UPS
- Payment such as PayPal, World Pay
- Marketing services such as Facebook, Instagram.
- Professional advisors handling your order in the warehouse
If Equine Clearance discovers that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. Equine Clearance will record all data breaches regardless of their effect.
International data transfers:
Equine Clearance will not transfer HR-related personal data to countries outside the EEA.
Individuals are responsible for helping Equine Clearance keep their personal data up to date. Individuals should let Equine Clearance know if data provided to the Equine Clearance changes, for example if an individual move to a new house or changes his/her bank details.
Individuals may have access to the personal data of other individuals of our customers in the course of their employment. this is the case, Equine Clearance relies on individuals to help meet its data protection obligations to staff and to customers.
Individuals who have access to personal data are required:
- to access only data that they have authority to access and only for authorised purposes;
- not to disclose data except to individuals inside Equine Clearance who have appropriate authorisation;
- to keep data secure by complying with rules on access to premises, computer access, including password protection.
- not to remove personal data, or devices containing or that can be used to access personal data, from Equine Clearance’s premises without adopting appropriate security measures such as encryption or password protection to secure the data and the device; and
- not to store personal data on local drives or on personal devices that are used for work purposes.
Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the Equine Clearance 's disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.
Equine Clearance will provide training to all individuals about their data protection responsibilities as part of the induction process.
Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.