Devey (Holdings) Ltd
1.4 The GDPR defines "personal data" as any information relating to an identified or identifiable natural person (a "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.
1.5 The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
2. The Data Protection Principles
2.1 This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:
(a) Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
(b) Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
(c) Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
(d) Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.
(e) Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.
(f) Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.
3. The Rights of Data Subjects
3.1 The GDPR sets out the following rights applicable to data subjects (please refer to the parts of the protection policy indicated for further details):
4. Lawful, Fair, and Transparent Data Processing
4.1 The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:
(a) The data subject has given consent to the processing of their personal data for one or more specific purposes;
(b) The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;
(c) The processing is necessary for compliance with a legal obligation to which the data controller is subject;
(d) The processing is necessary to protect the vital interests of the data subject or of another natural person;
(e) The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or
(f) The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
4.2 If the personal data in question is "special category data" (also known as "sensitive personal data") (for example, data concerning the data subject's race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:
(a) The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);
(b) The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);
(c) The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
(d) The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;
(e) The processing relates to personal data which is clearly made public by the data subject;
(f) The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;
(g) The processing is necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;
(h) The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;
(i) The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or
(j) The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.
5. Data Collected
5.1 We may collect the following information about you. When you contact us using the "Contact Us" form on our websites, we collect your name, address, telephone number & email address and any comments that you provide. This information is used by us to respond to your comments.
5.2 When you make a reservation over the telephone or in person we collect your title, first name, surname, address, email address, telephone number and payment card details. Additionally, we ask for the title, first name and surname of a person for each hotel room that you book or leisure reservation made. This allows us to hold the reservation & identify you on arrival, contact you in relation to your stay with us, acts as a guarantee, for example for any damage to or smoking in the room, and also to contact you with regards to special offers & promotions should you wish to 'opt in' to marketing services.
5.3 We will not retain personal information in an identifiable format for any longer than is necessary.
6. Third Parties
6.1 Where personal information is processed on our behalf by third parties, such as for the purpose of processing payment of your booking, we put measures in place to keep information secure.
6.2 We will also disclose any of your personal information (in line with applicable data protection laws) to any third party where we are under a legal duty to do so in order to comply with any legal obligation, or in order to enforce or protect any of our rights, property or safety (or those of our customers).
7. Security of your data
7.1 Please see our Data Protection policy for full details on how we make sure your data is safe.
8. Subject Access Request
8.1 You have the right to request a copy of the personal information that we hold about you. To obtain a copy of this information please contact us and we will provide you with a Subject Access Request form.
This Policy shall be deemed effective as of 24 May 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
This Policy has been approved and authorised by:
Name: Mrs Sarah Devey
Date: 24th May 2018
Due for Review by: 24th May 2019
Signature: S Devey