Personal identification information
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, subscribe to the newsletter, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, email address. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.
Non-personal identification information
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
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How we use collected information
Company may collect and use Users personal information for the following purposes:
- To improve customer service
Information you provide helps us respond to your customer service requests and support needs more efficiently.
- To personalize user experience
We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
- To send periodic emails
We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Site.
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
Sharing your personal information
We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
Third party websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website's own terms and policies.
Food Safety Solutions 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 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 we understand the rules governing their use of the personal data to which they have access in the course of their work.
In particular, this policy requires us to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.
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 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 and security vetting
Checking references, ensuring safe working practices monitoring and managing staff access to systems and facilities, staff absences, administration and assessments
Monitoring staff conduct, disciplinary matters
Marketing our business and Improving services
‘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, physical address, email address, financial and payment details, tax information, details of certificates and diplomas, education and skills, marital status, nationality, employment visa details, job title, and CV.
Special categories of personal data
Special categories of data include information about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings, and genetic and biometric information —any use of special categories of personal data should be strictly controlled in accordance with this policy.
‘Data controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law.
‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Food Safety Solutions shall comply with the principles of data protection (the Principles)
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.
Limited for its purpose
Data can only be collected for a specific purpose.
Any data collected must be necessary and not excessive for its purpose.
The data we hold must be accurate and kept up to date.
We cannot store data longer than necessary.
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. We are responsible for keeping a written record of how all the data processing activities that we are responsible for comply with each of the Principles. This must be kept up to date and must be approved by the DPO.
To comply with data protection laws and the accountability and transparency Principle of GDPR, we must demonstrate compliance. We are responsible for understanding our 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:
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. Ensure that any data we are responsible for managing has a written lawful basis approved by the DPO. It is our responsibility to check the lawful basis for any data we are working with and ensure all of our actions comply the lawful basis. At least one of the following conditions must apply whenever we process personal data:
We hold recent, clear, explicit, and defined consent for the individual’s data to be processed for a specific purpose.
The processing is necessary to fulfil or prepare a contract for the individual.
We have a legal obligation to process the data (excluding a contract).
Processing the data is necessary to protect a person’s life or in a medical situation.
Processing necessary to carry out a public function, a task of public interest or the function has a clear basis in law.
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.
Deciding which condition to rely on
If you are making an assessment of the lawful basis, you must first establish that the processing is necessary. This means the processing must be a targeted, appropriate way of achieving the stated purpose. We cannot rely on a lawful basis if we can reasonably achieve the same purpose by other means.
Remember that more than one basis may apply, and we should rely on what will best fit the purpose, not what is easiest.
Consider the following factors and document our answers:
What is the purpose for processing the data?
Can it reasonably be done in a different way?
Is there a choice as to whether or not to process the data?
Who does the processing benefit?
After selecting the lawful basis, is this the same as the lawful basis the data subject would expect?
What is the impact of the processing on the individual?
Are you in a position of power over them?
Are they a vulnerable person?
Would they be likely to object to the processing?
Are you able to stop the processing at any time on request, and have you factored in how to do this?
Our commitment to the first Principle requires us to document this process and show that we have considered which lawful basis best applies to each processing purpose, and fully justify these decisions.
We must also ensure that individuals whose data is being processed by us are informed of the lawful basis for processing their data, as well as the intended purpose. This should occur via a privacy notice. This applies whether we have collected the data directly from the individual, or from another source.
If you are responsible for making an assessment of the lawful basis and implementing the privacy notice for the processing activity, you must have this approved by the DPO.
Special categories of personal data
What are special categories of personal data?
Previously known as sensitive personal data, this means data about an individual which is more sensitive, so requires more protection. This type of data could create more significant risks to a person’s fundamental rights and freedoms, for example by putting them at risk of unlawful discrimination. The special categories include information about an individual’s:
trade union membership
biometrics (where used for ID purposes)
In most cases where we process special categories of personal data, we will require the data subject’s explicit consent to do this unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.
The condition for processing special categories of personal data must comply with the law. If we do not have a lawful basis for processing special categories of data that processing activity must cease.
Analysing and documenting the type of personal data we hold
Checking procedures to ensure they cover all the rights of the individual
Identify the lawful basis for processing data
Ensuring consent procedures are lawful
Implementing and reviewing procedures to detect, report and investigate personal data breaches
Store data in safe and secure ways
Assess the risk that could be posed to individual rights and freedoms should data be compromised
Fully understand your data protection obligations
Check that any data processing activities you are dealing with comply with our policy and are justified
Do not use data in any unlawful way
Do not store data incorrectly, be careless with it or otherwise cause us to breach data protection laws and our policies through your actions
Comply with this policy at all times
Raise any concerns, notify any breaches or errors, and report anything suspicious or contradictory to this policy or our legal obligations without delay
Responsibilities of the Data Protection Officer
Keeping the Board updated about data protection responsibilities, risks and issues
Reviewing all data protection procedures and policies on a regular basis
Arranging data protection training and advice for all staff members and those included in this policy
Answering questions on data protection from staff, board members and other stakeholders
Responding to individuals such as clients and employees who wish to know which data is being held on them by us
Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing
Responsibilities of the IT Manager
Ensure all systems, services, software and equipment meet acceptable security standards
Checking and scanning security hardware and software regularly to ensure it is functioning properly
Researching third-party services, such as cloud services the company is considering using to store or process data
Responsibilities of the Marketing Manager
Approving data protection statements attached to emails and other marketing copy
Addressing data protection queries from clients, target audiences or media outlets
Co-ordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy
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.
We must keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
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 stored on CDs or memory sticks must be encrypted or password protected and locked away securely when they are not being used
The DPO must approve any cloud used to store data
Servers containing personal data must be kept in a secure location, away from general office space
Data should be regularly backed up in line with the company’s backup procedures
Data should never be saved directly to mobile devices such as tablets or smartphones
All servers containing sensitive data must be approved and protected by security software
All possible technical measures must be put in place to keep data secure
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.
Transferring data internationally
There are restrictions on international transfers of personal data. We must not transfer personal data abroad, or anywhere else outside of normal rules and procedures without express permission from the DPO.
Your acceptance of these terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.