Introduction

Radcliffe Butchers is committed to protecting the rights and freedoms of data subjects and safely and securely processing their data in accordance with all of our legal obligations.

We hold personal data about our employees, clients, suppliers and other individuals for a variety of business purposes.

This policy sets out how we seek to protect personal data and ensure that our staff understand the rules governing their use of the personal data to which they have access in the course of their work.

Definitions

Business purposes

The purposes for which personal data may be used by us:

 

Personnel, administrative, financial, regulatory, payroll and business development purposes.

 

Business purposes include the following:

-     Compliance with our legal, regulatory and corporate governance obligations and good practice

-     Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests

-     Ensuring business policies are adhered to (such as policies covering email and internet use)

-     Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking

-     Investigating complaints

-     Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments

-     Monitoring staff conduct, disciplinary matters

-     Marketing our business

-     Improving services

 

Personal data

‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular 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, mental, economic, cultural or social identity of that natural person.

Personal data we gather may include: individuals' phone number, email address, Home Address, financial and pay details.

Data controller

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Scope

This policy applies to all staff, who must be familiar with this policy and comply with its terms.

This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.

The principles

Radcliffe Butchers shall comply with the principles of data protection (the Principles) enumerated in the EU General Data Protection Regulation. We will make every effort possible in everything we do to comply with these principles. The Principles are:

1. Lawful, fair and transparent

Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.

2. Limited for its purpose

Data can only be collected for a specific purpose.

3. Data minimisation

Any data collected must be necessary and not excessive for its purpose.

4. Accurate

The data we hold must be accurate and kept up to date.

5. Retention

We cannot store data longer than necessary.

6. Integrity and confidentiality

The data we hold must be kept safe and secure.

Accountability and transparency

We must ensure accountability and transparency in all our use of personal data. We must show how we comply with each Principle. You are responsible for keeping a written record of how all the data processing activities you are responsible for comply with each of the Principles.

To comply with data protection laws and the accountability and transparency Principle of GDPR, we must demonstrate compliance. You are responsible for understanding your particular responsibilities to ensure we meet the following data protection obligations:

• Fully implement all appropriate technical and organisational measures

• Maintain up to date and relevant documentation on all processing activities

• Conducting Data Protection Impact Assessments

• Implement measures to ensure privacy by design and default, including:

  • Data minimisation

  • Pseudonymisation

  • Transparency

  • Allowing individuals to monitor processing

  • Creating and improving security and enhanced privacy procedures on an ongoing basis

 

 

Our procedures

Fair and lawful processing

 

We must process personal data fairly and lawfully in accordance with individuals’ rights under the first Principle. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.

 

If we cannot apply a lawful basis (explained below), our processing does not conform to the first principle and will be unlawful. Data subjects have the right to have any data unlawfully processed erased

 

Lawful basis for processing data

We must establish a lawful basis for processing data. It is your responsibility to check the lawful basis for any data you are working with and ensure all of your actions comply the lawful basis. At least one of the following conditions must apply whenever we process personal data:

 

1. Consent

 

We hold recent, clear, explicit, and defined consent for the individual’s data to be processed for a specific purpose.

 

1. Contract

 

The processing is necessary to fulfil or prepare a contract for the individual.

 

1. Legal obligation

 

We have a legal obligation to process the data (excluding a contract).

 

1. Vital interests

 

Processing the data is necessary to protect a person’s life or in a medical situation.

 

1. Public function

 

Processing necessary to carry out a public function, a task of public interest or the function has a clear basis in law.

 

1. Legitimate interest

 

The processing is necessary for our legitimate interests. This condition does not apply if there is a good reason to protect the individual’s personal data which overrides the legitimate interest.

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Accuracy and relevance

 

We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

 

Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO.

 

 

Storing data securely

 

• In cases when data is stored on printed paper, it should be kept in a secure place where unauthorised personnel cannot access it

• Printed data should be shredded when it is no longer needed

• Data stored on a computer should be protected by strong passwords that are changed regularly. We encourage all staff to use a password manager to create and store their passwords.

 

Data retention

 

We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner consistent with our data retention guidelines.

 

Privacy notices

• We do not keep track of any cookies or browsing history

• Any purchase history is strictly for record keeping purposes and will not be passed on to any third-party organisation.

• By using our website, you agree to the privacy policy and use of your data

• We aim to keep your data secure and we aim to respond to any data deletion requests in a prompt manner.

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