Privacy Policy

Edmund A. Stephens Limited

GDPR Privacy Statement 2018

BACKGROUND:

Edmund A. Stephens Limited, incorporating Liverpool Pallet & Case and also MDL Timber understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Our Information

Edmund A. Stephens Limited, incorporating Liverpool Pallet & Case and also MDL Timber.

Limited Company registered in England under company number 01376043.

Registered address: 37 Bankhall Street, Liverpool, L20 8JD.

VAT number: GB324823467.

Email: info@lpcc.co.uk

Telephone: 0151 922 9952

Postal Address: 37 Bankhall Street, Liverpool, L20 8JD

2. What Does This Notice Cover?

This notice explains how we use your personal data: how we collect, hold, and process it. It also explains your rights under the law relating to your personal data.

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
  2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
  5. The right to restrict (i.e. prevent) the processing of your personal data.
  6. The right to object to us using your personal data for a particular purpose or purposes.
  7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

5. What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):

  • Name;
  • Address;
  • Email address;
  • Telephone number;
  • Business name;
  • Job title;
  • Payment information;
  • Bank details (when applying for a credit account)
  • Your personal data is obtained from the following third parties:
  • Creditsafe for the purpose of credit checking when we enter a business relationship,
  • CIFS for the purpose of credit checking when we enter a business relationship.

When using our website, we may also collect some or all of the following:

  • IP address;
  • Geographical location;
  • Browser software;
  • Operating system;
  • Referral source;
  • Page views and website navigation paths;
  • Information regarding the length of your visit, frequency and timing of the use of our services

6. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

  • Providing and managing your account.
  • Supplying our products and/or services to you. Your personal details are required in order for us to enter into a contract with you.
  • Personalising and tailoring our products and/or services for you.
  • Communicating with you. This may include responding to emails or calls from you.
  • For conducting credit checks prior to starting a business relationship and at various times throughout it.
  • For the purposes of creating a bill for our products and services.
  • For managing delivery of jobs at your site, home or other delivery address as requested by you.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

7a. Customer Quotes

At this stage you will provide details of the job you require, we will also need your personal details, name, phone number and/or email and a delivery address if the job is to be delivered.

Paper quotes are held for 3 months from the month they are submitted at which point they are destroyed.

Email quotes will be held for up to 12 months as per the rolling email deletion policy.

Quotes that are accepted as jobs to go ahead then become sales orders and are kept for 7 years as per our legal requirements.

7b. Human Resources Data

Data can be held for varying time lengths, in the case of employees (Human Resource Records) we will keep relevant personal data in their paper personnel file and electronically. We have the following data retention policies.

We will keep information fully for the entire period of their employment

We will destroy all information not required for compliance within 6 months of the end of their employment if there has been no further involvement (tribunals etc).

Where there has been further involvement we will retain the files for 6 months after the end of any further involvement such as tribunal etc.

Compliance information, such as proof we are paying the minimum wage will be retained until up to 90 days after our statutory requirement to keep it has been fulfilled.

Health and Safety data will be retained for life in a secure, electronic format.

7c. Customer & Supplier Data

For Suppliers and Customers data can also be held for varying time lengths. We have the following data retention policies.

We will retain all data relating to credit account customers and cash sales account customers for 7 years as per our legal accounting requirements, even if the customer ceases to trade with us.

We will destroy all other information not required for compliance (such as emails) within 12 months of completion of an order if there is not dispute. If there is any dispute the entire file(s) will be retained until the dispute is resolved.

8. How and Where Do You Store or Transfer My Personal Data?

We will store or transfer your personal data:

  • Within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein.

  • Within the United States by companies that have signed the EU Model Contract Clauses and applicable Data Processing Amendments

This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

9. Do You Share My Personal Data?

We may sometimes share your details with the following third parties to supply products AND/OR services to you on our behalf. These may include payment processing and delivery. In some cases, those third parties may require access to some or all of your personal data that we hold.

  • Helsby & Longden (Palletforce), Delivery services.
  • Swift Dispatch, Delivery services.
  • Tuffnells, Delivery services.
  • Credit Safe and CIFS for credit checking.
  • Prophet Collections for debt collection.
  • RAC Telematics, tracking our own fleet of delivery vehicles/drivers.
  • Tachograph Analysis, monitoring our fleet of delivery vehicles/drivers.
  • USIC, our IT support.
  • Sage, Our HR & Accounting software provider.
  • Smashbang Online Media, our website and point-of-sale system provider
  • Google Inc, our website analytics and email provider
  • Linode LLC, our website hosting provider
  • Webfaction, our email and data backup provider

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 4 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: info@lpcc.co.uk, stating “GDPR access request” in the subject line.

Telephone number: 0151 922 9952.

Postal Address: 37 Bankhall Street, Liverpool, L20 8JD.

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available in the privacy section of our website.

Compliance Statement

Edmund A. Stephens Limited, incorporating Liverpool Pallet & Case and also MDL Timber.

GDPR Compliance Statement May 2018

Edmund A. Stephens Limited, incorporating Liverpool Pallet & Case and also MDL Timber are committed to ensuring the security and protection of the personal information that we hold and/or process & to providing a consistent and compliant approach to data protection.

We have a legal basis to hold and process personal data under Article 6 of the GDPR, our business falls primarily under 4 of the sub-sections

Article 6, section 1(a) – consent, customer or supplier has expressly given their consent to their data being processed by us.

Article 6, section 1(b) – contract – we have entered into a contract of sale/purchase with the customer or supplier and need their personal data to be able to fulfil that contract.

Article 6, section 1(c) – compliance – we have a legal responsibility to hold data, e.g. (but not limited to) sales invoices for VAT purposes or employee data to ensure compliance with minimum wage requirements.

Article 6, section 1(f) – legitimate interest – we need to hold and process personal data in order to run our business, this includes but is not limited to; storing account customer information, storing supplier information, holding quotations on file, storing emails for reference.

We have reviewed the information we keep, where it is kept and for how long.

We do not use data for marketing purposes and will not sell or pass it on to third party organisations unless the is a legitimate interest in our doing so.

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