When we process your personal data we are required to comply with the General Data Protection Regulation 2016 and associated laws (“Data Protection Laws”).
Your personal data includes all the information we hold that identifies you or is about you, including but not limited to information you give us by completing enquiry forms on the Website or by corresponding with us by phone, email or otherwise. The information you give us may include your name, email address, postal address, date of birth, location data and in some cases opinions that we document about you.
Everything we do with your personal data counts as processing it, including collecting, storing, amending, transferring and deleting it. We are therefore required to comply with the Data Protection Laws to make sure that your information is properly protected and used appropriately.
This notice provides information about the personal data we process about you, why we process it and how we process it.
Reward is the data controller of the personal data you provide. We have appointed Tim Stafford as our privacy officer and he will have day to day responsibility for ensuring we comply with the Data Protection Laws and dealing with any requests we receive from individuals exercising their rights under the Data Protection Laws.
Generally, it will be your responsibility as the data controller (this term is explained in the Data Protection Laws) to ensure you provide us with data for processing activities for which you have identified a legal basis for such processing. We will not accept responsibility for your providing us data without a legal basis for doing so.
Why do we process your personal data?
Exactly what personal data we process, and why we process it, will depend upon the relationship you have with Reward
We may need personal data from you to be able to enter into a contract with you and provide you with all the information you need. If we do not receive that personal data from you, we may be unable to fulfil our obligations to you.
Where we require personal data from you for our own purposes we normally do so on the following legal bases as defined under GDPR:
- Contract entry and performance: in order to commence working with you as a client we are legally required to take certain steps, such as assuring ourselves of your identity and credit checking. In order to do so we require some personal data from you. During the course of our contract with you we require to continue processing personal data about you to enable us to deliver the service(s) to you.
- Our legitimate interests: We may use your personal data on the basis of our own legitimate interests in promoting our business and developing our services and evaluating our performance. This may include business to business marketing which you may opt-out of at any time. You can opt out at any time from marketing activity by emailing us at [email protected]
- Consent: You may give us your consent to promote our business and develop our services, for example by you requesting to be included in our Reward newsletters and events. You can opt out at any time by emailing us at [email protected]
- Legal obligations: where we have legal obligations to process your personal data we will, insofar as is possible without breaching any other duty we owe in respect of such legal obligation, advise you of our intention to process your data for their purposes.
If none of the grounds set out above applies, including if we require special categories of personal data from you, we will obtain separate consent from you to the processing of your personal data. You can withdraw your consent at any time. This won’t affect the lawfulness of any processing we carried out prior to you withdrawing your consent.
Who will receive your personal data?
We only transfer your personal data to the extent we need to. Recipients of your personal data include:
- group companies of Reward where this is necessary for ordinary entry and management of contracts;
- legal and financial advisors in relation to our entry and management of any contract we have with you;
- professional organisations that provide services relating to the provision of our services, for example valuation specialists and surveyors;
- credit reference organisations in relation to any credit reference, customer identification or anti-money laundering checks; or
- third party providers of network services, for example email distribution systems and data centre providers.
We share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006. This may involve transferring your data outside the European
Economic Area (EEA). We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.
How long will we keep your personal data?
We will retain your personal data for 7 years. We retain your information for this period in case any issues arise or in case you have any queries. Your information will be kept securely at all times. Following the end of the 7 year period, your files and personal data we hold about you will be permanently deleted or destroyed. If we are required to obtain your consent to send you marketing communications, any information we use for this purpose will be kept until you withdraw your consent, unless we have other legitimate reasons to retain the data.
What are your rights?
You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/). These rights apply for the period in which we process your data.
Access to your data
You have the right to ask us to confirm that we process your personal data, as well as access to / copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this notice.
We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee.
We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we’ll let you know.
Rectification of your data
If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.
Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:
- where we no longer need your personal data for the purpose for which we collected it;
- where we have collected your personal data on the grounds of consent and you withdraw that consent;
- where you object to the processing and we don’t have any overriding legitimate interests to continue processing the data;
- where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR); and
- where the personal data has to be deleted to comply with a legal obligation.
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.
Right to restrict processing
In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:
- if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
- if you have objected to us processing the data – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
- if the processing is unlawful; or
- if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:
- where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
- where we carry out the processing by automated means.
We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.
Right to object
You are entitled to object to us processing your personal data:
- if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
- for direct marketing purposes (including profiling); and/or
- for the purposes of scientific or historical research and statistics.
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
Automated decision making
Automated decision making means making a decision solely by automated means without any human involvement. This would include, for example, an online credit reference check that makes a decision based on information you input without any human involvement. It would also include the use of an automated clocking-in system that automatically issues a warning if a person is late a certain number of times (without any input from HR, for example).
We don’t carry out any automated decision making using your personal data.
Your right to complain about our processing
If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website – https://ico.org.uk/concerns/.
If you have any questions or would like more information about the ways in which we process your data, please contact [email protected].