Section 1
Who we are and why we care about our customers data
The Traditional Welsh Sausage Company Ltd is a private company registered in England and Wales, company number 03699399. Our registered office is; The Traditional Welsh Sausage Company Ltd, 18 High St, Conwy, LL32 8DE.
Here at The Traditional Welsh Sausage Company Ltd we are committed to maintaining the trust and confidence of our customers, we take your privacy very seriously. This document explains how we collect, store and handle your personal data. Please take time to read and understand this policy and please ask if you have any questions, comments or concerns.
For the purpose of this document the data controller of the information you provide us is The Traditional Welsh Sausage Company Ltd (referred to in this policy as “we” or “us”). The term “data controller” is a legal phrase used to describe the person or entity that controls the way information is used and processed. We are committed to ensuring that your privacy is protected.
The purpose of this notice is to:
• set out the types of personal data that we collect
• explain how and why we collect and use your personal data
• explain when and why we will share personal data and with other organisations
• explain the rights and choices you have when it comes to your personal data
This Policy applies to you if you use our services (referred to in this Policy as “our Services”). Using our Services means:
- Visiting our website
- Taking part in promotions & competitions
- Contacting us with a query or feedback about any of our services, this includes contacting us online, in person, over the phone or anywhere where this Policy is posted.
- Entering our recruitment process
- Visit our premises
Section 2
Information we hold about you & who we share this with
General Personal Data
When you use our services, you may provide us with your general personal details, including your full name, email addresses, phone numbers, date of birth and title.
We may share your general personal details with other organisations (which are specific to the product/service you are receiving as listed below), as well as some general core service providers such as IT/Security companies or similar. We will only send our service providers the necessary personal data that they need to fulfil their service to us, this includes the transfer of information between ourselves and our sister company “Edwards of Conwy Ltd.”.
External service providers will each have their own privacy policy however, we will always set out our expectations in relation to keeping your personal data secure and hold them fully responsible for meeting those expectations.
In addition to this we may also share your personal data in the following circumstances:
• If the law or a public authority says we must share the personal data
• If we need to share personal data in order to establish, exercise or defend our legal rights and property.
• As part of the purchase, merger or reorganisation of the business. The organisation receiving your personal data can use your personal data in the same way as us; or to any other successors in title to our business.
Additional Personal Data (by service)
In addition to the above, you may also provide the specific information required for the services listed below. This information may be shared with the respective third parties (also listed below).
When you use our website, we may collect:
• Information about your online browsing behaviour on our Website
• Information about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers)
This information may be shared with: Our website developers, Google Analytics and our chosen courier company.
When you take part in promotions & competitions we may collect:
• Circumstantial personal data specific to the promotions / competition format, for example you may be asked to share an image, make a comment or give feedback.
This information may be shared with: Our chosen courier company.
When you contact us with a query (or if we contact you) or when you take part surveys or questionnaires about our services, we may collect:
• Circumstantial personal data you provide about yourself in relation to the query
• Your feedback and contributions to customer surveys and questionnaires
When you visit our premises, we may collect:
- Time and date logs of any visits to any of our sites.
- CCTV Images
- Images of your face
- Details of any recent travel
- Health information (see additional notes under “Special Category Data”)
This information may be shared with: Food Safety Standards Agency, the Local Authority and any other government authority if they ask us to (but only if us doing so is lawful).
When you enter our recruitment process, we may collect:
• Job position applied for
• Home address
• Details on your education & qualifications
• Previous & current employment details (incl. pay)
• Health information (see additional notes under “Special Category Data”)
• Driving licence and conviction information (see additional notes under “Special Category Data”)
• The contact details of your references
• Your signature
• Other information as provided within your CV (if applicable)
This information may be shared with: Your listed references, the Food Safety Standards Agency and the Local Authority.
What we use your information for and our legal bases for doing so
We use the personal information we hold about you for a number of different purposes, which we list below. Under data protection law we need to have a valid legal basis for using your personal information, these are set out below in italics.
- To enable you to access our services.
- To enable us to provide you with the highest possible level of customer service.
- To carry out market research to better understand your views on our products and services.
- To manage and improve our day to day operations.
- To carry out internal research to improve the range of products offered and associated products and services we can offer you and to help identify new products and services we may wish to offer in the future.
- To manage promotions, competitions and any other marketing activity you may take part in.
- To verify your identity
- To detect and prevent fraud and other illegal activities (and to assist regulators, trade bodies and law enforcement agencies in relation to the same)
- To comply with the law
(a) Consent: you the individual have given clear consent for us to process your personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract we have with you the individual, or because you have asked us to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect you the individual’s personal data which overrides those legitimate interests.
Special category personal data
We use the special category personal data we hold about you for a number of different purposes, which we list below. Data protection law prohibits us from processing any special category personal data unless we have a valid legal basis for using your personal information (as listed above) and additionally, can also satisfy at least one of the specific special category data processing conditions laid down by data protection law, these are set out below in italics.
We will also use the special category personal data we hold about you for the following reasons:
- To comply with and demonstrate compliance with best practice and any applicable laws.
- To comply and demonstrate compliance with any regulatory requirements such as the Food Standard Agencies “Regulatory Guidance and Best Practice Advice for Food Business Operators”.
In these cases the condition(s) we rely upon for processing the information is that the processing is necessary for reasons of public interest in the area of public health & processing is necessary for the establishment, exercise or defence of legal claims.
We will not otherwise process your sensitive or special category information unless you have given us explicit consent to do so.
Protection of your personal data
We know how important it is to securely store, protect and manage your personal data. We enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data. We use computer safeguards such as firewalls and data encryption, and we enforce physical access controls to our buildings and files to keep this data safe. To ensure internal confidentiality we only authorise access to employees who need it to carry out their job responsibilities, we use full login and password controls on our computer systems.
International Transfer of your Information
We do not transfer any of your personal data outside the European Economic Area.
How long we keep your information for
To make sure we meet our legal data protection and privacy obligations, we only hold on to your information for as long as we actually need it for the purposes we acquired it in the first place. The length of time each piece of data is kept varies, a full breakdown on how long we keep your personal data for can be found on the “Data Retention Schedule” (available by request).
Further Information
External links within our website
Our Website may contain links to other websites operated by other organisations that have their own privacy policies. Please make sure you read the terms and conditions and privacy policy carefully before providing any personal data on a website as we do not accept any responsibility or liability for websites of other organisations. The full terms and conditions of use for our website can be found here.
Google analytics & Cookies in relation to our website
The Traditional Welsh Sausage Company (www.thewelshbutcher.co.uk) use non-unique cookies on this website for the purpose of website performance. These cookies collect anonymous information on how people use our Site. For example, we may use cookies to help us understand how you arrive at our Site, browse or use our Site and highlight areas where we can improve. The data stored by these cookies never shows personal details from which your individual identity can be established. We use Google Analytics, for example, to anonymously track website usage and activity. You are presented with the option to update your cookie preferences during your first visit to our site, you can update these at any time by clearing the cookies within your browser and revisiting our website (where the same option to update your cookie preferences will appear). Users are advised to take necessary steps within their web browsers’ security settings should they want to block all cookies from this website.
Social Media Platforms
Communication, engagement or any other action taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions, as well as the privacy policies, held with each social media platform respectively. Users are advised to use social media platforms wisely and communicate / engage upon them with due diligence in regard to their own privacy and personal details. The Traditional Welsh Sausage Company Ltd may use social sharing buttons which help share web content directly from web pages to the social media platform in question when such buttons are clicked upon. We advise users that using such social sharing buttons is at the user’s discretion and note that the social media platform may track and save your request to share a web page respectively through your social media account.
Shortened Links in Social Media
The Traditional Welsh Sausage Company Ltd may share web links to relevant web pages through our social media accounts. By default, some social media platforms shorten lengthy URL’s (web addresses) to shorter formats. Users are advised to take caution and make a judgement before clicking any shortened URL’s published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine URL’s are published, many social media platforms are prone to spam and hacking, and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
Competitions on Social Media Platforms
From time to time we may run promotional activity / competitions via our social media platforms. Users entering such activities will have their public screen name shared and be contacted via the social media platform in question for the sole purpose of notifying the winner. Each promotion/competition will be served with its own terms and conditions, the data we collect is outlined earlier on in this document (see earlier section “Additional Personal Data (by service)”).
The Recruitment Process
The information collected during the recruitment process (see earlier section “Additional Personal Data (by service)”) is done so in order to carry out the necessary processing required for recruitment under the legal basis of legitimate interests. This information will be used for the purpose or recruitment within The Traditional Welsh Sausage Company and its Sister Company (Edwards of Conwy Ltd) only.
If your application for employment is successful, any personal data gathered during the recruitment process will be transferred to your Human Resources file and retained for the duration of your employment (and in some cases beyond), you will be provided with a staff privacy notice outlining this.
If your application for employment is unsuccessful, we will hold your data on file for (up to) 4 weeks after the end of the relevant recruitment process. If you authorise us to do so (using a tick box) then we will keep your personal data on file for (up to) a further 5 months for consideration for future employment opportunities. At the end of that total period, or once you withdraw your consent, your data will be securely destroyed. You can contact us to withdraw your consent at any time. Opting not to provide this consent will not have an adverse effect on your application.
Section 3
Individual Rights and where to go if you want more information
The Information Commissioner’s Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them on the ICO’s website.
Data protection legislation provides individuals with a number of different rights in relation to their data. For example, you have the right to ask us whether we hold information about you and if so, for us to give you certain details about that information and/or the information itself. This right is commonly known as a “subject access request”. Certain exemptions and conditions apply to this right.
There are other rights which you may also be able to exercise, such as the right to have inaccurate personal data rectified, to object to the processing of personal data, to object to direct marketing, to the erasure of personal data or to have the processing of your personal data restricted as well as the right to have electronic data made portable. All of these rights are subject to certain conditions and exemptions.
For more information on your rights as an individual please visit the ICO’s website: http://www.ico.gov.uk/for_the_public.aspx
You can exercise these rights by contacting us at any time, if you wish to do so, or obtain further information about these rights, please contact us using the details provided at the end of policy.
Ability to withdraw consent
Where your personal data is processed on the basis of your consent or explicit consent, you have the right to withdraw your consent to the processing at any time. You can do this by contacting us using the details provided at the end of policy. Any withdrawal of consent will not affect the lawfulness of any processing of your personal data based on consent before the withdrawal is notified.
Accuracy
If any or your personal details change during the time you make use of our services you should notify us using the details provided at the end of this policy and provide us with the updated accurate information.
You can make a complaint to the ICO at anytime about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first. We will always do our best to solve any problems you may have.
Updates to this privacy policy
We review the ways we use your information regularly. In doing so, we may change what kind of information we collect, how we store it, who we share it with and how we act on it. Consequently, we will need to change this privacy policy from time to time to keep it accurate and up-to-date.
We will keep this policy under regular review to ensure it is accurate and kept up to date. This policy was last updated on 05/08/2020.
Contact us
You are welcome to get in touch with us to discuss your information at any time. Our contact details are here:
The Traditional Welsh Sausage Company
Units 1 & 2 CRWST Business Park Ffordd Sam Pari, Conwy LL32 8HH
office@edwardsofconwy.co.uk
01492 576800