BOX MARKETING GDPR PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
What is the purpose of this document?
Box Marketing is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are a client or a third party supplier with whom we have a working relationship.
It makes you aware of how and why your personal data will be used, namely for the purposes of the working with you to fulfil our business requirements as a client or supplier, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we hold about you
Alongside our terms of business, we will collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, work addresses and telephone numbers
- Location of employment or workplace.
- CCTV footage and other information obtained through electronic means such as swipe card records or sound recordings (e.g. recorded telephone conversations)
- Information about your use of our information and communications systems.
How is your personal information collected?
We collect personal information about clients and suppliers through the agreements in place to engage in work together, either directly from our contacts or sometimes information passed on from a work colleague or associate.
We may collect additional personal information in the course of job-related activities throughout the period of us working together.
How we will use information about you
We need all the categories of information in the list above (see paragraph “The kind of information we hold about you”) primarily to allow us to perform our contract with you, to perform our contract with employees or workers and to enable us to comply with legal obligations . In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Administering the contract we have entered into with you.
- Business management and planning, including accounting and auditing.
- To monitor your use of our information and communication systems to ensure compliance with our IT policies.
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
- To arrange attendance to any corporate events
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Why might you share my personal information with third parties?
We will only share your personal information with the specific third parties for the purposes of administering the contract we have entered with you.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will retain your personal information for a period of twelve months after we have concluded a business activity with you. We retain your personal information for that period so that we can identify, in the event of any queries the appropriate contact information relating to any activity.
Rights of access, correction, erasure, and restriction
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact firstname.lastname@example.org