FW Hall Privacy Statement
The Purpose of this privacy statement is to explain, in general terms, how FW Hall & Son Ltd (FWH) processes your personal data from the moment it is collected to the point it is deleted or destroyed. Other ‘specific to customer’ privacy notices will be provided when needed.
The Role of FWH in data protection terms is that of a data controller where it determines the purpose and use of personal data we collect. Once received it becomes the responsibility of the FWH privacy officer (PO) to ensure that it is processed in line with the latest UK legislation.
Should you have a query regarding the contents of this privacy statement or about the way FWH processes your personal data, please contact the PO in the first instance. The PO can be contacted by email using email@example.com or by writing to:
The Privacy Officer, FW Hall & Son Ltd, Wendover Road, Rackheath, Norwich, NR13 6LH.
The sort of personal data processed by FWH will be basic contact information for the purposes of communicating with customers. Typically, this will be names, addresses, telephone numbers and an email address.
The way we collect or receive your personal data is either:
- Directly from you, starting at the time of your initial enquiry either through the web page contact form, a direct call or visit to our premises, by email or through a face to face meeting with a member of the FWH staff; or
- From an existing customer or business associate who has referred you to us and with whom we have checked that they have had your consent for us to contact you.
FWH’s duty of confidentiality means that FWH staff will treat your personal data in confidence. FWH uses reasonable organisational and technical measures to ensure personal data is safe guarded. Access is limited to only those members of staff who need it.
FWH also expects the same duty of confidentiality of all third-parties with whom we need to share your personal data for the purposes of fulfilling our contractual obligations to you. All such third-parties are subject to a due diligence review.
FWH will process personal data against a lawful basis; such instances are described below:
- Where we have a legitimate interest to respond to your general enquiries, or where we have obtained your details from a referee prior to any preparation for a sale;
- Where we have a legitimate interest to retain your contact details after the delivery of your specified product and any related guarantee has expired, whichever is the later; This is so we can contact you about any relevant product related issues and also to keep you updated with our latest products and services, but only when we think these will be relevant to you. We will confirm with you how you would like to be contacted by us;
- Where you have given your consent* relating to a specific purpose such as being contacted by us to you make you aware of our products that we believe will be of interest to you;
- To comply with our legal obligations; and
- To fulfil our contractual obligations to you either as a customer as set out in any related ‘Terms and Conditions’ or as a supplier/ service provider to FWH.
*Please be aware that you have the right to withdraw your consent at any time.
In all cases the processing of personal data by FWH shall be:
- Processed lawfully, fairly and transparently;
- Collected for specified, explicit and legitimate purposes;
- Adequate, relevant and limited to what is necessary (and no more);
- Accurate and, when necessary, updated;
- Kept for no longer than is necessary; and
- Processed in a manner that ensures appropriate security.
FWH will never sell your personal data and will only share your personal data when it’s absolutely necessary, with some or all of the following third parties:
- Company accountant & the legal firm appointed by FWH;
- HMRC for invoice related activity;
- Courier companies for the delivery of products when necessary; and
- Unspecified recipients but only when compelled to do so for legal reasons.
FWH will process your data in the UK. First line personal data processing takes place at the UK premises and backed-up using a cloud service provider whose servers are also based in the UK. It should be noted that no personal data is stored on the FWH website server.
FWH follows a retention schedule to determine the length of time it holds different types of personal data of the customer or, when appropriate, a customer’s nominated carer. The key points of the schedule are shown below:
- If you make an enquiry but choose not to purchase one of our products, we will delete any information we have collected about you after 2 years;
- If FWH has contacted you as a result of information sourced by a referrer but you choose not to purchase one of our products, we will delete any information we have collected about you after 2 years;
- If FWH has received your consent to hold your contact details for the purposes of keeping you informed about our products, we will retain it indefinitely until such a time you withdraw your consent, or we inform you that we will be deleting your records from our database;
- If you have been a customer, we will retain your data indefinitely after our contract with you has ended unless you request that your personal data is erased from our records. Assuming we don’t have another legal basis for processing it, we will fulfil your request;
- Financial records and invoices, which includes your personal data, will be retained for 6 years after the end of the current tax year of processing; and
By exception, documentation that includes your personal data may be retained by FWH beyond the schedule, but only for a specific purpose and only when FWH believes there is a legitimate interest or has a legal obligation to do so.
At the end of the retention schedule FWH will either return, destroy or delete/ anonymise your personal data and any associated emails or relevant documentation. If it is technically impractical to delete electronic copies of personal data, it will put it beyond operational use.
The General Data Protection Regulation defines the rights that you have (although these do not apply in all situations). For convenience, these rights are shown below:
- Right to be informed as to how your personal data is being processed by FWH – this is done through this statement and/or separate FWH privacy notices when appropriate;
- Right to access your personal data held by FWH which is done by making a ‘Data Subject Access Request’ (DSAR) to the FWH privacy officer;
- Right to rectification of your personal data if you believe FWH has collected it incorrectly or it needs to be updated;
- Right to erasure of your personal data for which FWH no longer has an overriding legitimate purpose to process;
- Right to restrict processing under certain circumstances, during which time your personal data will be out of operational use until the related matter is resolved;
- Right to data portability of your personal data in a machine-readable version, as you have provided but only applicable to data provided with your consent or under contract;
- Right to object to FWH processing your personal data for which it does not have a legal or contractual obligation; and
- Rights related to automated decision making and profiling (however FWH does not use these techniques in its decision making).
Further details on data subjects’ rights can be found on the Information Commissioner’s Office (ICO) website: https://ico.org.uk.
Raising concerns, exercising rights or making queries about FWH’s processing of personal data can be done by contacting the FWH privacy officer. Please be aware that FWH will need to confirm your identity before proceeding with any request. It is likely that you will be asked to provide some documentation to prove your identity.