This Policy sets out the obligations of CKB Ltd ® and its group brands including Bar Amigos ® and Lanyards Tomorrow ™ (“the Company”) with regard to data protection and the rights of website users (“data subjects”) in respect of their personal data under the Data Protection Act 1998 (“the Act”). Under the Act, “personal data” is defined as data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller (the Company in this context), and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.
This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures set out herein must be followed at all times by the Company and the Company must satisfy itself that any other parties working on behalf of the Company deal with personal data appropriately.
The Company is committed not only to the letter of the law but also to the spirit of the law and places a high premium 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.
The Company is registered with the Information Commissioner as a data controller under the register held by the Information Commissioner pursuant to Section 19 of the Act.
This Policy aims to ensure compliance with the Act. The Act sets out eight principles with which any party handling personal data must comply. All personal data:
The Company does not process any sensitive personal data as defined under the Act on its website.
Under the Act, data subjects have the following rights:
Personal data is defined by the Act as data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.
The Company only holds personal data that is directly relevant to its dealings with a given data subject. That data will be collected, held, and processed in accordance with the data protection principles and with this Policy. The data which may be collected, held and processed by the Company includes:
Any and all personal data collected by the Company (as detailed in Part 4 of this Policy) is collected in order to ensure that the Company can provide the best possible service to its customers, and can work effectively with its partners, associates and affiliates and efficiently manage its employees. The Company may also use personal data in meeting certain obligations imposed by law. This includes retaining information for as long as required for financial accounting purposes.
Certain data collected by the Company, such as IP addresses, certain information gathered by cookies, pseudonyms and other non-identifying information will nonetheless be collected, held and processed to the same standards as personal data.
Personal data may be disclosed within the Company, provided such disclosure complies with this Policy. Personal data may be passed from one department to another in accordance with the data protection principles and this Policy. Under no circumstances will personal data be passed to any department or any individual within the Company that does not reasonably require access to that personal data with respect to the purpose(s) for which it was collected and is being processed.
In particular, the Company shall ensure that:
The Company shall ensure that all of its employees comply with the following when working with personal data:
The Company shall ensure that the following measures are taken with respect to the collection, holding and processing of personal data:
A data subject may make a subject access request (“SAR”) at any time to find out more about the information which the Company holds about them.
Upon receipt of a SAR the Company shall have a maximum period of 40 calendar days within which to respond fully. The following information will be provided to the data subject:
As a data controller, the Company is required to notify the Information Commissioner’s Office that it is processing personal data. The Company is registered in the register of data controllers, registration number: ZA185276.
This Policy shall be deemed effective as of 7th June 2016. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.