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SILVEY MASTER PRIVACY POLICY

Contents

1.     Introduction.

2.     Terminology.

3.     Security.

4.     Purpose of this Privacy Policy.

5.     What do we do with your Personal Data.

5.1   If you are a Silvey Customer or Potential Customer

5.1.1        Why we use your personal data.

5.1.2        How we obtain your personal information and the types of personal information we may obtain 

5.1.3        Our legal basis for using your personal data.

5.1.4        Who we share your data with.

5.1.5        The transfer of your personal data to a Country or International Organisation outside of the European Union.

5.1.6        How long we keep hold of your data.

5.1.7        Statutory or Contractual Requirement

5.1.8        Automated Decision Making & Profiling.

5.2   If you visit our Website.

5.2.1        Why we use your personal data.

5.2.2        Our legal basis for using your personal data.

5.2.3        Who we share your data with.

5.2.4        The transfer of your personal data to a Country or International Organisation outside of the European Union.

5.2.5        How long we keep hold of your data.

5.2.6        Statutory or Contractual Requirement

5.2.7        Automated Decision Making & Profiling.

5.2.8        Cookie Policy.

5.3   If you are someone who registers for, or attends our Exhibitions/Conferences and provides us with your contact details (e.g. business card) directly.

5.3.1        Why we use your personal data.

5.3.2        Our legal basis for using your personal data.

5.3.3        Who we share your data with.

5.3.4        The transfer of your personal data to a Country or International Organisation outside of the European Union.

5.3.5        How long we keep hold of your data.

5.3.6        Statutory or Contractual Requirement

5.3.7        Automated Decision Making & Profiling.

5.4   If you contact us directly via telephone or email to make an enquiry with regards to our services

5.4.1        Why we use your personal data.

5.4.2        Our legal basis for using your personal data.

5.4.3        Who we share your data with.

5.4.4        The transfer of your personal data to a Country or International Organisation outside of the European Union.

5.4.5        How long we keep hold of your data.

5.4.6        Statutory or Contractual Requirement

5.4.7        Automated Decision Making & Profiling.

5.5   If you are a Silvey Supplier

5.5.1        Why we use your personal data.

5.5.2        Our legal basis for using your personal data.

5.5.3        Who we share your data with.

5.5.4        The transfer of your personal data to a Country or International Organisation outside of the European Union.

5.5.5        How long we keep hold of your data.

5.5.6        Statutory or Contractual Requirement

5.5.7        Automated Decision Making & Profiling.

5.6   If you are a Silvey Recruitment Applicant

5.6.1        Why we use your personal data.

5.6.2        Our legal basis for using your personal data.

5.6.3        Who we share your data with.

5.6.4        The transfer of your personal data to a Country or International Organisation outside of the European Union.

5.6.5        How long we keep hold of your data.

5.6.6        Statutory or Contractual Requirement

5.6.7        Automated Decision Making & Profiling.

5.7   If you a Visitor to Silvey.

5.7.1        Why we use your personal data.

5.7.2        Our legal basis for using your personal data.

5.7.3        Who we share your data with.

5.7.4        The transfer of your personal data to a Country or International Organisation outside of the European Union.

5.7.5        How long we keep hold of your data.

5.7.6        Statutory or Contractual Requirement

5.7.7        Automated Decision Making & Profiling.

6.     Silvey’s Contact Details

7.     Your Rights

7.1   Access to your personal data.

7.2   Correcting your personal data.

7.3   Restriction of Processing of your personal data.

7.4   Object to Processing.

7.5   Erasure (also known as “the right to be forgotten”)

7.6   Portability.

7.7   Withdrawal of consent

7.8   Complaints

8.     Changes to our Privacy Policy.

9.     Employee/Contractor Privacy Policy.

9.1   Security.

9.2   Purpose of this Privacy Policy.

9.3   What we do with the Personal Data or our Employees & Contractors

9.3.1        Why we use your personal data & our legal basis for doing so.

9.3.2        Who we share your data with.

9.3.3        The transfer of your personal data to a Country or International Organisation outside of the European Union.

9.3.4        How long we keep hold of your data.

9.3.5        Statutory or Contractual Requirement

9.3.6        Automated Decision Making & Profiling.

9.4   Thomas Silvey’s Contact Details

9.5   Your Rights

9.5.1        Access to your personal data.

9.5.2        Correcting your personal data.

9.5.3        Restriction of Processing of your personal data.

9.5.4        Object to Processing.

9.5.5        Erasure (also known as “the right to be forgotten”)

9.5.6        Portability.

9.5.7        Withdrawal of consent

9.5.8        Complaints

9.6   Changes to our Privacy Policy.

10.   GLOSSARY OF TERMS.

 

1. Introduction

Thomas Silvey Limited was originally formed in the 1870’s, operating from Bristol. Today the Company operates from our office in Yate.

In February 2009 the company was acquired as part of the Mabanaft Group and operates  independently under the Thomas Silvey name. The scope and the content of this document covers all aspects of Thomas Silvey Ltd.

The Company’s core business is the sale and distribution of petroleum products to consumers and the provision of network bunkering services to road transport companies through its freehold and managed filling stations.

The customer base includes retail outlets and end users of petroleum products over a wide spectrum of industry.

 

2. Terminology

Below is some quick guidance on terminology to help you clearly understand this Policy

Personal data is any information relating to an identified or identifiable living person. 

The Data Controller is a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.  In the context of this Policy, Silvey is the Data Controller.

Other terms are defined in the Glossary at the end of the document.

 

3. Security

Silvey is committed to protecting your personal data and privacy.  We are in the process of becoming certified to an internationally recognised security standard (ISO 27001), and we are already certified to a quality standard (ISO 9001) with a UKAS accredited body.

We have security measures in place designed to prevent the loss of data, preserve data integrity, and to control access to the data and know that ensuring the accuracy and security of your personal data is essential to retaining your confidence and trust. 

 

4. Purpose of this Privacy Policy

The purpose of this privacy policy is to describe, in cases where Silvey is the Data Controller, why and how we collect and use your personal data and provides information about your rights.  It applies to personal data provided to us, both by individuals themselves or by others.  We may use personal data provided to us for any of the purposes described in this privacy policy or as otherwise stated at the point of collection.

When collecting and using personal data, our policy is to be fair, lawful and transparent about why and how we process personal data. 

To find out more about our specific processing activities, please go to the relevant sections of this policy.  

Topics:

What we do with your Personal Data

How to contact us

Your Rights

Changes to our Privacy Policy

 

5. What do we do with your Personal Data

Please go to the sections of this policy that are relevant to you, to find out more about what we do with your personal data: -

5.1 If you are a Silvey Customer or Potential Customer

5.1.1 Why we use your personal data

We use your data for the following purposes: -

To identify if you have registered with the Corporate Telephone Preference Service, Telephone Preference Service and/or have notified Silvey that you do not wish to be contacted and/or receive direct marketing information regarding our products, services and activities;

Unless we have identified you do not wish to receive marketing information, as per above – to contact you directly in the future regarding our products, services, and/or events (i.e. via telephone, postal and electronic marketing);

To send you communication regarding Silvey’s activities.

5.1.2 How we obtain your personal information and the types of personal information we may obtain

Your personal information is directly given by you or collected from the company website and managed via Microsoft Dynamics. Data has also been provided to us by our marketing partners Experian and Dunn and Bradstreet.

We process the following types of personal information in relation to you - e.g. (this is not an exhaustive list): -

  • Title
  • Name
  • Job Title
  • Contact Details (Work address, Work Email address, work telephone number).

5.1.3 Our legal basis for using your personal data

The processing of your personal data is based upon the lawful basis of Legitimate Interests – as we feel that as an existing customer you may find value in knowing about similar products and services we provide.

5.1.4 Who we share your data with

We may share your information with: -

Technology Providers who we engage to support our operations and/or host our data including

  • Fuelsoft – Software Supplier to the Fuel distribution and Fuel Card Industry
  • Interface Essential Ltd - Website Provider
  • Dunraven - Fuel monitoring systems
  • Solution IP - Call recording
  • Chorus IT- IT infrastructure and maintenance
  • Bottomline Technologies- Financial management system
  • TMC – Fleet Services Software
  • Survey Monkey – Customer Feedback
  • Graydons - Credit Reference Agency
  • Third Party Hauliers - Oil Delivery
  • Marquard & Bahls Group – Sanction List check

5.1.5 The transfer of your personal data to a Country or International Organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

5.1.6 How long we keep hold of your data

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for your personal data and other documentary evidence is seven years.

5.1.7 Statutory or Contractual Requirement

The provision of your personal data is not a statutory or contractual requirement, or a requirement necessary to enter into a contract, nor are you obliged to provide the personal data.

5.1.8 Automated Decision Making & Profiling

We do not make any decisions in relation to your personal data, solely by automated means without any human involvement (e.g we do not conduct automated decision making).

Neither do we conduct any automated processing of personal data to evaluate certain things about you (e.g. we do not conduct profiling).

 

5.2 If you visit our Website  

5.2.1 Why we use your personal data

We use your data for the following purposes: -

If you visit our website – your personal data is used to: -

  • To identify if you have registered with the Corporate Telephone Preference Service, Telephone Preference Service and/or have notified Silvey that you do not wish to be contacted and/or receive direct marketing information regarding our products, services and activities;
  • Unless we have identified you do not wish to receive marketing information, as per above – to contact you directly in the future regarding our products, services, and/or events (i.e. via telephone, postal and electronic marketing);
  • To send you communications regarding Silvey’s activities.

If you send an enquiry via our website – your personal data is used to: -

  • To identify if you have registered with the Corporate Telephone Preference Service, Telephone Preference Service and/or have notified Silvey that you do not wish to be contacted and/or receive direct marketing information regarding our products, services and activities;
  • Unless we have identified you do not wish to receive marketing information, as per above – to contact you directly in the future regarding our products, services, and/or events (i.e. via telephone, postal and electronic marketing);
  • To send you communications regarding Silvey’s activities.

If you submit a job application via our website – please refer to Section 5.6

5.2.2 Our legal basis for using your personal data

The processing of your personal data is based upon the lawful basis of: -

  • Legitimate Interests – as you have shown an interest in Silvey and/or it’s services and therefore further information is likely to be of interest. 
  • Legal Obligation – For cases where you may have objected to marketing, we also have a legal obligation - to hold some personal data, albeit limited, in order to ensure no more marketing is sent to you.

5.2.3 Who we share your data with

We may share your information with: -

  • Technology Providers who we engage to support our operations and/or host our data including
  • Fuelsoft – Software Supplier to the Fuel distribution and Fuel Card Industry
  • Interface Essential Ltd- Website Provider
  • Dunraven - Fuel monitoring systems
  • Solution IP - Call recording
  • Chorus IT- IT infrastructure and maintenance
  • Bottomline Technologies- Financial management system
  • TMC – Fleet Services Software

5.2.4 The transfer of your personal data to a Country or International Organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

5.2.5 How long we keep hold of your data

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for your personal data and other documentary evidence is seven years.

5.2.6 Statutory or Contractual Requirement

The provision of your personal data is not a statutory or contractual requirement, or a requirement necessary to enter into a contract, nor are you obliged to provide the personal data.

5.2.7 Automated Decision Making & Profiling

We do not make any decisions in relation to your personal data, solely by automated means without any human involvement (e.g we do not conduct automated decision making).

Neither do we conduct any automated processing of personal data to evaluate certain things about you (e.g. we do not conduct profiling).

5.2.8 Cookie Policy

To improve your experience on our site, we may use 'cookies'. Cookies are an industry standard and most major web sites use them. A cookie is a small text file that our site may place on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. You can set your browser not to accept cookies (click here for guidance). However, in a few cases some of our website  features may not function as a result.

Our website uses Microsoft Dynamics, a service which monitors website traffic data.

Our website also uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.

By using this website, you consent to the processing of data about you by Google in the manner described in Google's Privacy Policy which is an external site which describes the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by the Google external site.

Silvey also uses interfaces with social media sites such as Facebook, LinkedIn, and others. If you choose to "like" or "share" information from this website through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your visits to this site with other Personal Information.

 

5.3 If you are someone who registers for, or attends our Exhibitions/Conferences and provides us with your contact details (e.g. business card) directly

5.3.1 Why we use your personal data

When you register with us directly to attend an exhibition, your personal data is used to:

  • Register you for the event (so we know how many people are attending);
  • Identify if you have registered with the Corporate Telephone Preference Service, Telephone Preference Service and/or have notified Silvey that you do not wish to be contacted and/or receive direct marketing information regarding our products, services and activities;
  • Unless we have identified you do not wish to receive marketing information, as per above – to contact you directly (or via our Telemarketing partners) in the future regarding our products, services, and/or events (i.e. via telephone, postal and electronic marketing);
  • To send you communications regarding Silvey’s activities.

When you provide your business contact details at an exhibition, your personal data is used to: -

  • Identify if you have registered with the Corporate Telephone Preference Service, Telephone Preference Service and/or have notified Silvey that you do not wish to be contacted and/or receive direct marketing information regarding our products, services and activities;
  • Unless we have identified you do not wish to receive marketing information, as per above – to contact you directly (or via our Telemarketing partners) in the future regarding our products, services, and/or events (i.e. via telephone, postal and electronic marketing);
  • To send you communications regarding Silvey’s activities.

5.3.2 Our legal basis for using your personal data

The processing of your personal information is based upon the lawful basis of: -

Legal Obligation - For cases where you may have objected to marketing, we also have a legal obligation to hold some personal data, albeit limited, in order to ensure no more marketing is sent to you.

5.3.3 Who we share your data with

We may share your information with: -

  • Technology Providers who we engage to support our operations and/or host our data including
  • Fuelsoft – Software Supplier to the Fuel distribution and Fuel Card Industry
  • Interface Essential Ltd- Website Provider
  • Dunraven - Fuel monitoring systems
  • Chorus IT- IT infrastructure and maintenance
  • TMC – Fleet Services Software

5.3.4 The transfer of your personal data to a Country or International Organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

5.3.5 How long we keep hold of your data

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for your personal data and other documentary evidence seven years.

5.3.6 Statutory or Contractual Requirement

The provision of your personal data is not a statutory or contractual requirement, or a requirement necessary to enter into a contract, nor are you obliged to provide the personal data.

5.3.7 Automated Decision Making & Profiling

We do not make any decisions in relation to your personal data, solely by automated means without any human involvement (e.g. we do not conduct automated decision making).

Neither do we conduct any automated processing of personal data to evaluate certain things about you (e.g. we do not conduct profiling).

 

5.4 If you contact us directly via telephone or email to make an enquiry with regards to our services  

5.4.1 Why we use your personal data

We use your data for the following purposes: -

  • To progress an opportunity;
  • Identify if you have registered with the Corporate Telephone Preference Service, Telephone Preference Service and/or have notified Silvey that you do not wish to be contacted and/or receive direct marketing information regarding our products, services and activities;
  • Unless we have identified you do not wish to receive marketing information, as per above – to contact you directly (or via our Telemarketing partners) in the future regarding our products, services, and/or events (i.e. via telephone, postal and electronic marketing);
  • To send you communication regarding Silvey’s activities.

5.4.2 Our legal basis for using your personal data

The processing of your personal information is based upon the lawful basis of: -

  • Legitimate Interest – as you have expressed an interest in our services and activities and for contacting you in relation to future events and/or sending communications;

Legal Obligation - For cases where you may have objected to marketing, we also have a legal obligation to hold some personal data, albeit limited, in order to ensure no more marketing is sent to you.

5.4.3 Who we share your data with

We may share your information with: -

  • Technology Providers who we engage to support our operations and/or host our data including
  • Fuelsoft – Software Supplier to the Fuel distribution and Fuel Card Industry
  • Interface Essential Ltd- Website Provider
  • Dunraven - Fuel monitoring systems
  • Solution IP - Call recording
  • Chorus IT- IT infrastructure and maintenance
  • Bottomline Technologies- Financial management system
  • TMC – Fleet Services Software

5.4.4 The transfer of your personal data to a Country or International Organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

5.4.5 How long we keep hold of your data

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for your personal data and other documentary evidence is seven years.

5.4.6 Statutory or Contractual Requirement

The provision of your personal data is not a statutory or contractual requirement, or a requirement necessary to enter into a contract, nor are you obliged to provide the personal data.

5.4.7 Automated Decision Making & Profiling

We do not make any decisions in relation to your personal data, solely by automated means without any human involvement (e.g we do not conduct automated decision making).

Neither do we conduct any automated processing of personal data to evaluate certain things about you (e.g. we do not conduct profiling).

 

5.5 If you are a Silvey Supplier  

5.5.1 Why we use your personal data

We use your data for the following purposes: -

  • To maintain a relationship with you in relation to our orders and your services (e.g. in relation to service delivery activities, invoicing and ongoing communication/relationship management);
  • To send you communications regarding Silvey’s activities.

5.5.2 Our legal basis for using your personal data

The processing of your personal information is based upon the lawful basis of: -

  • Business to Business contacts: Legitimate Interests – to maintain a relationship with you in relation to our orders and your services (e.g. in relation to service delivery activities, invoicing and ongoing communication/relationship management);
  • Business to Business contacts: Legitimate Interests - For the purpose of contacting you in relation to future events and/or sending communications;
  • Business to Business contacts & Business to Consumer contacts: Consent – for inclusion in any press articles and/or case studies, in which case we will always obtain your fully informed, freely given, consent (i.e. we will obtain your permission;

5.5.3 Who we share your data with

We may share your information with: -

  • Technology Providers who we engage to support our operations and/or host our data including
  • Fuelsoft – Software Supplier to the Fuel distribution and Fuel Card Industry
  • Interface Essential Ltd- Website Provider
  • Solution IP - Call recording
  • Chorus IT- IT infrastructure and maintenance
  • Bottomline Technologies- Financial management system

5.5.4 The transfer of your personal data to a Country or International Organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

5.5.5 How long we keep hold of your data

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for your personal data and other documentary evidence is seven years after end fo commercial relationship.

5.5.6 Statutory or Contractual Requirement

The provision of your personal data is not a statutory or contractual requirement, or a requirement necessary to enter into a contract, nor are you obliged to provide the personal data.

5.5.7 Automated Decision Making & Profiling

We do not make any decisions in relation to your personal data, solely by automated means without any human involvement (e.g we do not conduct automated decision making).

Neither do we conduct any automated processing of personal data to evaluate certain things about you (e.g. we do not conduct profiling).

 

5.6 If you are a Silvey Recruitment Applicant

5.6.1 Why we use your personal data

We use your data for the following purposes: -

  • Consider you for a recruitment vacancy;

5.6.2 Our legal basis for using your personal data

The processing of your personal information is based upon the lawful basis of: -

  • Legitimate Interest – as you have expressed an interest in working with us and we will be able to consider your application and contact you in this respect.

5.6.3 Who we share your data with

We may share your information with: -

  • Technology Providers who we engage to support our operations and/or host our data Chorus IT and Solution IP.  

5.6.4 The transfer of your personal data to a Country or International Organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

5.6.5 How long we keep hold of your data

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for your personal data and other documentary evidence is detailed in Section 9.3.4 (if successful) or 6 months if unsuccessful.

5.6.6 Statutory or Contractual Requirement

The provision of your personal data is not a statutory or contractual requirement, or a requirement necessary to enter into a contract, nor are you obliged to provide the personal data.

5.6.7 Automated Decision Making & Profiling

We do not make any decisions in relation to your personal data, solely by automated means without any human involvement (e.g we do not conduct automated decision making).

Neither do we conduct any automated processing of personal data to evaluate certain things about you (e.g. we do not conduct profiling).

 

5.7 If you a Visitor to Silvey  

5.7.1 Why we use your personal data

We use your data for the following purposes: -

  • For security and health and safety purposes (knowing who is in our building and when).

5.7.2 Our legal basis for using your personal data

The processing of your personal data is based upon the lawful basis of Legitimate Interests – as it is important to ensure the safety of yourself and others and also to ensure the security of our information.  

5.7.3 Who we share your data with

We may share your information with: -

  • Technology Providers who we engage to support our operations and/or host our data ADT CCTV supplier.

5.7.4 The transfer of your personal data to a Country or International Organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

5.7.5 How long we keep hold of your data

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for your personal data and other documentary evidence is 2 years after your last visit with us.

5.7.6 Statutory or Contractual Requirement

The provision of your personal data is not a statutory or contractual requirement, or a requirement necessary to enter into a contract, nor are you obliged to provide the personal data.

5.7.7 Automated Decision Making & Profiling

We do not make any decisions in relation to your personal data, solely by automated means without any human involvement (e.g we do not conduct automated decision making).

Neither do we conduct any automated processing of personal data to evaluate certain things about you (e.g. we do not conduct profiling).

 

6. Silvey’s Contact Details

The Data Controller is Thomas Silvey Limited (registered in England under registration no. 00360922 and with its registration address at 5th Floor, Portland House, Cardinal Place, London, SW1E 5RS).

Silvey’s Company’s Data Protection Officer is Mr David Hatherell.

If you have any questions about this Privacy Policy or how and why we process personal data, please contact us via any of the routes below: -

Post:

David Hatherell
Thomas Silvey Limited
Unit 5
Badminton Road Trading estate
Yate
Bristol
BS37 5NS

Email: data-protection@Silvey.co.uk

Phone: Data protection Officer 01454 333 020

 

7. Your Rights

Under certain circumstances, you have the rights under data protection laws in relation to your personal data.  These rights are summarised below but if you would like more information on these rights, please go the ICO’s website.  Additionally, if you wish to exercise any of these rights listed below, please contact us using any of the contact details provided here.

7.1 Access to your personal data

You have a right of access to personal data held by us as a Data Controller.  We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (1 month under GDPR).

7.2 Correcting your personal data

You have a right to request amendment(s) to your personal data.  Wherever practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make the necessary amendments based on the updated information.

7.3 Restriction of Processing of your personal data

In certain circumstances, you have the right to request the restriction or suppression of your personal data.  This effectively allows you to limit the way that we use your persona data. 

7.4 Object to Processing

In certain circumstances, you have the right to object to the processing of your personal data.  This effectively allows you to ask us to stop processing your personal data.

Where we have told you that any use of information is based on ‘legitimate interest’, you can raise an objection to that use. When you make an objection, we’ll have up to one month to respond to you. We will stop using the information in this way unless we disagree that we should because of a compelling legal justification for continuing to use it. We’ll always tell you what the justification is.

You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other parts of the Mabanaft Group and/or our Marketing Partners. If you no longer wish to be contacted for marketing purposes, please click here. Link to marketing@silvey.co.uk

7.5 Erasure (also known as “the right to be forgotten”)

In certain circumstances, you have the right to request the erasure of your personal data.

7.6 Portability

In certain circumstances, you may have the right to obtain and reuse your own personal data, that you provided to us, for your own purposes across different services.  This data will be provided in a structured, commonly used and machine-readable format and we can transmit this data directly to other parties at your request.

7.7 Withdrawal of consent

Where we process your personal data based on consent, you have a right to withdraw consent at any time. 

If you would like to request to withdraw your consent, please contact us using the contact details provided here.  Alternatively, to stop receiving our Marketing emails, please click on the unsubscribe link in the any of the emails we have sent to you. 

7.8 Complaints

In the event you wish to complain about our use of your personal data, please send an email with the details of your complaint to data-protection@Silvey.co.uk.  We will look into and respond to any complaints we receive.

You also have a right to lodge a complaint with the Information Commissioner's Office (ICO) (the UK’s data protection regulator).  For further information on your rights and how to complain to the ICO, please refer to the ICO website: www.ico.org.uk.

 

8. Changes to our Privacy Policy

We keep our privacy policy under regular review and we will place any updates on this web page.

If we believe that the changes are material, we’ll let you know by posting the changes on this website.

This privacy policy was last updated on 23/05/18.

 

9. Employee/Contractor Privacy Policy

9.1 Security

Silvey is committed to protecting your personal data and privacy.  We are in the process of becoming certified to an internationally recognised security standard (ISO 27001), and we are already certified to a quality standard (ISO 9001) with a UKAS accredited body.

We have security measures in place designed to prevent the loss of data, preserve data integrity, and to control access to the data and know that ensuring the accuracy and security of your personal data is essential to retaining your confidence and trust.  We have security measures in place designed to prevent the loss of data, preserve data integrity, and to control access to the data and know that ensuring the accuracy and security of your personal data is essential to retaining your confidence. 

9.2 Purpose of this Privacy Policy

The purpose of this privacy policy is to describe why and how we collect and use your personal data and provides information about your rights.  We may use personal data provided to us for any of the purposes described in this privacy policy or as otherwise stated at the point of collection.

Personal data is any information relating to an identified or identifiable living person. 

When collecting and using personal data, our policy is to be fair, lawful and transparent about why and how we process personal data. 

To find out more about what we do with your data and your rights, please go to the relevant sections of this policy.  

Topics:

Add relevant links to the Sections in the document:

9.3 What we do with the Personal Data or our Employees & Contractors

9.3.1 Why we use your personal data & our legal basis for doing so

We use your data for the following purposes and legal bases: -

Legal Basis

Additional Condition to allow Processing of Special Category and or Criminal Data

Activity

Legitimate Interests

N/A

  • Contact details
  • CVs/Application Letters Employment References
  • CCTV
  • Operational & Administrative Purposes -e.g:-
  • Day to day operational communications (email)
  • Employee Development/ Appraisals
  • Business Continuity (staff contact details)
  • Travel, hire car, hotel, meeting bookings etc.
  • Recruitment reference checks

Processing is necessary for a contract

N/A

Employment Contract

Bank Details

Timesheets

 

Processing is necessary for Legal Obligation

Processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law

ID - Right to Work

Pension Provision

Working Time Directive

Consent

Explicit Consent

Company Website Photographs

 

9.3.2 Who we share your data with

We may share your information with: -

  • Benefit Providers
  • Insurance Brokered by Tailormade Financial Services Ltd:
    • Death in Service Insurance -Friends Life
    • Personal Accident Insurance – AIG Europe,
    • Prolonged Disability – Canada Life
  • Private Health – Axa PPP
  • Pension Provider – Royal London
  • MLR – Payroll Services
  • External Legal Advisors – Motor Industries Legal Services
  • Technology Providers who we engage to support our operations and/or host our data:
  • Chorus IT, Solution IP,
  • Marquard & Bahls Group Workday system which holds staff details for management of human resources.

9.3.3 The transfer of your personal data to a Country or International Organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

9.3.4 How long we keep hold of your data

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for your personal data and other documentary evidence is seven years after the end of employment.

9.3.5 Statutory or Contractual Requirement

The provision of your personal data is a contractual requirement in accordance with your employment contract.

9.3.6 Automated Decision Making & Profiling

We do not make any decisions in relation to your personal data, solely by automated means without any human involvement (e.g we do not conduct automated decision making).

Neither do we conduct any automated processing of personal data to evaluate certain things about you (e.g. we do not conduct profiling).

9.4 Thomas Silvey’s Contact Details

The Data Controller is Thomas Silvey Limited (registered in England under registration no. 00360922 and with its registration address at 5th Floor, Portland House, Cardinal Place, London, SW1E 5RS).

Silvey’s Company’s Data Protection Officer is Mr David Hatherell.

If you have any questions about this privacy policy or how and why we process personal data, please contact us via any of the routes below: -

Post:

David Hatherell
Thomas Silvey Limited
Unit 5
Badminton Road Trading estate
Yate
Bristol
BS37 5NS

Email: data-protection@Silvey.co.uk

Phone: Data Protection Officer 01454 333 020

9.5 Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  These rights are summarised below but if you would like more information on these rights, please go the ICO’s website.  Additionally, if you wish to exercise any of these rights listed below, please contact us using any of the contact details provided here.

9.5.1 Access to your personal data

You have a right of access to personal data held by us as a Data Controller.  We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (1 month under GDPR).

9.5.2 Correcting your personal data

You have a right to request amendment(s) to your personal data.  Wherever practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make the necessary amendments based on the updated information.

9.5.3 Restriction of Processing of your personal data

In certain circumstances, you have the right to request the restriction or suppression of your personal data.  This effectively allows you to limit the way that we use your persona data. 

9.5.4 Object to Processing

In certain circumstances, you have the right to object to the processing of your personal data.  This effectively allows you to ask us to stop processing your personal data.

Where we have told you that any use of information is based on ‘legitimate interest’, you can raise an objection to that use. When you make an objection, we’ll have up to one month to respond to you. We will stop using the information in this way unless we disagree that we should because of a compelling legal justification for continuing to use it. We’ll always tell you what the justification is.

9.5.5 Erasure (also known as “the right to be forgotten”)

In certain circumstances, you have the right to request the erasure of your personal data.

9.5.6 Portability

In certain circumstances, you may have the right to obtain and reuse your own personal data, that you provided to us, for your own purposes across different services.  This data will be provided in a structured, commonly used and machine-readable format and we can transmit this data directly to other parties at your request.

9.5.7 Withdrawal of consent

Where we process your personal data based on consent, you have a right to withdraw consent at any time. 

If you would like to request to withdraw your consent, please contact us using the contact details provided here.  Alternatively, to stop receiving our Marketing emails, please click on the unsubscribe link in the any of the emails we have sent to you. 

9.5.8 Complaints

In the event you wish to complain about our use of your personal data, please send an email with the details of your complaint to data-protection@Silvey.com.  We will look into and respond to any complaints we receive.

You also have a right to lodge a complaint with the Information Commissioner's Office (ICO) (the UK’s data protection regulator).  For further information on your rights and how to complain to the ICO, please refer to the ICO website: www.ico.org.uk.

 

9.6 Changes to our Privacy Policy

We keep our privacy policy under regular review and any changes are updated to this Policy and in the Employee Handbook.

If we believe that the changes made are material, we’ll let you know by sending you an email or message about the changes.

This privacy policy was last updated on 23/05/18

 

10. GLOSSARY OF TERMS

Consent (of the data subject): any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Controller (or Joint Controller): a person who, alone or jointly with others, determines the purposes and means of the processing of personal data.

Data Protection Officer (DPO): an individual or legal entity appointed to inform and advise the data controller or the data processor and the employees who carry out the processing of their obligations under the GDPR

Data Subject: An identifiable living person to whom the data relates to.

GDPR: General Data Protection Regulation

Personal data: Any information relating to an identified or identifiable living individual (‘data subject).

Processing: means any operation or set of operations which is performed on personal data or on sets of personal data, 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.

Processor: a person which processes personal data on behalf of the controller.

Special categories of data (often referred to as ‘Sensitive personal data’): Health data, genetic and biometric data (new under the GDPR), trade-union membership, data concerning health or sexual life, political opinions, religious and philosophical beliefs, criminal offences and racial or ethnic origin related data.