At Seawhite we take protection of our customers’ data very seriously. So, with the introduction of the General Data Protection Regulation (GDPR), this is what we are doing to keep your data safe.
Like any business, we need to collect and process your data in the normal course of a transaction, but what is changing under GDPR is that we now need to have a legitimate reason or ‘lawful basis for processing’, to collect and process your personal data. In Seawhite’s case, the main lawful basis allowing us to collect and process your data are ‘contractual’, and ‘legitimate interest’.
Sharing Your data securely with other related third parties is limited to providing your name and address to delivery companies acting on our behalf.
As these authorised contractors, may have different procedures and safeguards in place when handling your data, we will be inserting confidentiality clauses in all relevant third-party contracts.
At Seawhite, only authorised staff and IT system administrators have access to your data. Furthermore, all our staff receive training to help them understand and implement the latest data protection rules and guidelines. They also undertake refresher training on data protection and other important topics as part of our ongoing development and competency procedures.
In addition, our computer network is password protected and secured using role-based permissions, which means only staff with correct authorisation can view and process your personal data. Remote access to our computer network is permitted solely through a system of multi – factor authentication. Moreover, our network sits behind the most up-to-date application- based firewalls, providing real time antivirus and intrusion, provided by Sophos.
We also have round-the-clock hardware and software monitoring, logging and auditing of our network and all Seawhite users are subject to policies which cover computing equipment use, acceptable use, remote working and travel, email use and password use. Similarly, as part of our business continuation procedures, we perform daily backups on three separate systems (on and off site) of our core data.
Seawhite has invested extensively in Sophos Business Protection software which provides services such as a secure email gateway, XG Firewall, a secure web gateway, server protection, full disk encryption and an endpoint protection for users and data. Proof of compliance reporting is also available.
We treat the disposal of all hardware and storage media with the utmost care, ensuring it is dealt with securely and responsibly. All devices and storage media are either destroyed or recycled by a trusted contractor who meets the latest HMG InfoSec Standard.
Data that we hold:
Customers’ names, addresses, Suppliers’ bank account details, Customers’ email addresses, cookies on web site, social media posts.
Where is the data stored:
Emails, documents, databases, backups. All stored securely on -site server in locked server room.
Passwords, limited role access depending on rights given by administrator.
Length of time data kept for:
Individual electronic data transactions 2 years, as our data storage is limited. Hard copy paper transactions are kept for 6 years to comply with Inland Revenue obligations.
Nature of data we collect:
Purely of a transactional ‘contractual’ nature.
Person to be contacted to remove data: Geoff Thorpe, firstname.lastname@example.org
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
Who are Seawhite: Seawhite are Seawhite of Brighton Ltd
Explaining the legal basis underpinning our business:
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we might collect and process your data with your consent. For example, when you tick a box to receive email newsletters. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order an item from us that requires delivery, we’ll collect your address details to deliver your purchase, and pass them to our shipping company
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting Seawhite to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to send you, or make available, personalised offers.
We also combine the sales history of many customers to identify trends and ensure we can keep up with demand or develop new products/services.
We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
When do we collect your personal data?
When you visit our website, and use your account to buy products and services, or redeem vouchers from Seawhite on the phone, in our showroom or online.
When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
When you create an account with us.
When you purchase a product or service in our showroom or by phone but don’t have (or don’t use) an account.
When you engage with us on social media.
When you contact us by any means with queries, complaints etc.
When you ask Seawhite to email you information about a product or service.
When you enter a competition.
When you use our car parks which usually have CCTV systems operated for the security of both customers and Partners. These systems may record your image during your visit.
How and why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the best picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
How do we protect your data:
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
How long do we keep your data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of our normal 2 year retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Who do we share your personal data with?
We do not sell our data to third parties. We may share your data with delivery companies.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
• IT companies who support our website and other business systems.
• Operational companies such as delivery couriers.
• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
• We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
a. Take and fulfill customer orders
b. Administer and enhance the site and service
c. Issue a unique identifier (e.g. customer login)
d. Monitor customer account status beyond that required for individual purchases
e. Only disclose information to third-parties for goods delivery purposes
Credit card information where taken is gathered through the Sagepay gateway and conforms to PCI security standards.
What are your rights over your personal data:
An overview of your different rights
You have the right to request:
• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.
• Review by an employee of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
• You have the right to request a copy of any information about you that Seawhite holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection Officer, Seawhite Ltd, 2 Star Rd Trading Est, Partridge Green, West Sussex RH13 8RA, or email email@example.com. To ask for your information to be amended, please update your online account, or contact our Customer Services team.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
How can you stop the use of personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
• Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails.
• If you have an account, log in into your Seawhite account, visit the ‘My Account’ area and change your preferences.
• Write to Customer Services
• Contacting the regulator
if you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.