Privacy Policy

PRIVACY NOTICE Customers/ Suppliers

In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

A. DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

1. processing      is fair, lawful and transparent
2. data      is collected for specific, explicit, and legitimate purposes
3. data      collected is adequate, relevant and limited to what is necessary for the      purposes of processing
4. data      is kept accurate and up to date. Data which is found to be inaccurate will      be rectified or erased without delay
5. data      is not kept for longer than is necessary for its given purpose
6. data      is processed in a manner that ensures appropriate security of personal      data including protection against unauthorised or unlawful processing,      accidental loss, destruction or damage by using appropriate technical or      organisation measures
7. we      comply with the relevant GDPR procedures for international transferring of      personal data

B. TYPES OF DATA HELD

We keep several categories of personal data about you in order to carry out effective and efficient processes. We keep this data in a file relating to each customer/supplier and we also hold the data within our computer systems, for example, our accounts and freight systems.

Specifically, we hold the following types of data:

1. personal      details such as name, address, phone numbers
2. bank      account details

Whilst using our website, software applications or services, you may be required to provide personal information.  We will use this information to administer our website, application, sales, client databases and marketing material.  By providing Reef Logistics  with your telephone number, address and email details, you consent to Reef Logistics  contacting you, using that method.

C. COLLECTING YOUR DATA

You provide several pieces of data to us directly during any contract negotiation period, for example your name and address, and subsequently upon the start of your engagement, for example, your address details.

In some cases, we will collect data about you from third parties, such as intermediaries who may act as an introducer.

Personal data is kept in files or within the Company’s HR and IT systems.

D. LAWFUL BASIS FOR PROCESSING

The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement, in order to perform the contract we have with you or in pursuit of our legitimate interests.

The information below categorises the types of data processing we undertake and the lawful basis we rely on.

Activity requiring your data

Lawful basis

Carry out the contract that we have entered into with you   e.g. using your name, contact details

Performance of the contract

Ensuring you receive payment

Performance of the contract

Making decisions about who to enter into a contract with

Our legitimate interests

Business planning and restructuring exercises

Our legitimate interests

Dealing with legal claims made against us

Our legitimate interests

Preventing fraud

Our legitimate interests

Ensuring our administrative and IT systems are secure and   robust against unauthorised access

Our legitimate interests

E. SPECIAL CATEGORIES OF DATA

Special categories of data are data relating to your:

1. health
2. sex      life
3. sexual      orientation
4. race
5. ethnic      origin
6. political      opinion
7. religion
8. trade      union membership
9. genetic      and biometric data.

Most commonly, we will process special categories of data when the following applies:

1. you      have given explicit consent to the processing
2. we      must process the data in order to carry out our legal obligations
3. we      must process data for reasons of substantial public interest
4. you      have already made the data public.

We do not need your consent if we use special categories of personal data in order to carry out our legal obligations. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

F. FAILURE TO PROVIDE DATA

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract with you or performing the contract that we have entered into.

G. CRIMINAL CONVICTION DATA

We will only collect criminal conviction data where it is appropriate given the nature of the services you are to provide to us and where the law permits us. This data will usually be collected during contract negotiation, however, may also be collected during your engagement. We use criminal conviction data to determine your suitability, or your continued suitability for the engagement.

H. WHO WE SHARE YOUR DATA WITH

Employees within our company who have responsibility for recruitment, administration of payment and contractual benefits and the carrying out performance related procedures will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processed in line with GDPR.

We may share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

I. PROTECTING YOUR DATA

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

J. RETENTION PERIODS

We only keep your data for as long as we need it for, which will be at least for the duration of your engagement with us though in some cases we will keep your data for a period after your engagement has ended.

K. DATA SUBJECT RIGHTS

You have the following rights in relation to the personal data we hold on you:

1. the      right to be informed about the data we hold on you and what we do with it
2. the      right of access to the data we hold on you. More information on this can      be found in our separate policy on Subject Access Requests
3. the      right for any inaccuracies in the data we hold on you, however they come      to light, to be corrected. This is also known as ‘rectification’
4. the      right to have data deleted in certain circumstances. This is also known as      ‘erasure’
5. the      right to restrict the processing of the data
6. the      right to transfer the data we hold on you to another party. This is also      known as ‘portability’
7. the      right to object to the inclusion of any information
8. the      right to regulate any automated decision-making and profiling of personal      data.

More information can be found on each of these rights in our separate policy on your rights in relation to your data.

L. CONSENT

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.

M. MAKING A COMPLAINT

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.

N. DATA PROTECTION COMPLIANCE

Our appointed compliance officer in respect of our data protection activities is:

Wayne Amber 07480 941621