CKB Ltd
DSGVO Datenspeicherungspolitik
Juni 2018

1. Einleitung

Diese Richtlinie legt die Verpflichtungen der CKB Ltd ® und ihrer Konzernmarken fest, einschließlich Bar Amigos ® und Lanyards Tomorrow ® ("das Unternehmen"), einer in England unter der Nummer 07123102 ( Umsatzsteuer- Identifikationsnummer 991324508) registrierten Firma , deren registrierte Adresse St. Christopher's House ist , Ridge Road, Letchworth Garden City, Hertfordshire, SG6 1PT, England und deren Haupthandelsadresse Unit 5, Geschäftszentrum East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS, bezüglich der Aufbewahrung von gesammelten, gehaltenen und verarbeiteten personenbezogenen Daten von der Gesellschaft in Übereinstimmung mit der EU-Verordnung 2016/679 Datenschutz-Grundverordnung ("DSGVO").

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 which is in the possession of, or is likely to come into the possession of the data controller (the Company in this context).

The GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, 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. The Company does not handle such data in respect of customers but does for employees.

Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).

In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:

a) Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);

b) When the data subject withdraws their consent;

c) When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;

d) When the personal data is processed unlawfully (i.e. in breach of the GDPR);

e) When the personal data has to be erased to comply with a legal obligation; or

f) Where the personal data is processed for the provision of information society services to a child.

This Policy sets out the type(s) of personal data held by the Company and third party organisations it uses, the period(s) for which that personal data is to be retained before it is deleted or otherwise disposed of and the criteria for establishing and reviewing such retention period(s) if applicable.

For further information on other aspects of data protection and compliance with the GDPR, please refer to the Company’s Data Protection Policy/ Employee Data Protection Policy (as applicable).

2. Aims and Objectives

2.1 The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this Policy aims to ensure that the Company complies fully with its obligations and the rights of data subjects under the GDPR. This policy applies to both employee and non-employee data subjects.

2.2 In addition to safeguarding the rights of data subjects under the GDPR, by ensuring that excessive amounts of data are not retained by the Company without adequate justification, this Policy also aims to improve the speed and efficiency of managing data.

3. Scope

3.1 This Policy applies to all personal data held by the Company. Please note that any third-party data processors processing personal data on the Company’s behalf will have their own data privacy and data retention policies. The Company has sought to check third party compliance with the GDPR and an overview of third party involvement is contained in the Appendices to this policy. Please note, however, that whilst supporting transparency, the Company also needs to be mindful of its requirement to protect its business knowledge and security. Should a data subject wish to enquire further about details of third parties the Company works with, etc., please contact the Data Protection Officer at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Herts, SG6 2TS. Please also note that this policy does not cover third party operated marketplace sites which the Company may sell goods on such as Amazon which non-employee data subjects may purchase.

3.2 Personal data, as held by the Companyis/ may be stored in the following ways and in the following locations:

a) Computers permanently located in the Company’s UK premises;

b) Computers and mobile devices owned by employees, agents, and sub-contractors used in accordance with the Company’s Bring Your Own Device (“BYOD”) Policy;

c) Physical records stored in the Company’s UK premises; and

d) Third party companies processing personal data such as review companies are contained in the Appendix to this policy. The Company also makes use of a third-party server located in the UK (back up files for disaster recovery purposes may be securely stored in the EU meeting data protection requirements) and a third party electronic file share and storage system is covered by the EU-US privacy shield if stored outside the EU. Please refer to the Appendix.

4. Data Subject Rights and Data Integrity

All personal data held by the Company is held in accordance with the requirements of the GDPR and data subjects’ rights thereunder, as set out in the Company’s Data Protection Policy/ Employee Data Protection Policy.

4.1 Data subjects are kept fully informed of their rights, of what personal data the Company holds about them, how that personal data is used, and how long the Company will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined).

4.2 Data subjects are given control over their personal data held by the Company including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the right to restrict the Company’s use of their personal data, the right to data portability if possible, and further rights relating to automated decision-making and profiling.

5. Technical and Organisational Data Security Measures

5.1 The following technical measures are in place within the Company to protect the security of personal data. Please refer to the Company’s Data Protection Policy/ Employee Date Protection Policy for further details:

a) All emails containing personal data must be encrypted;

b) Personal data may only be transmitted over secure networks;

c) Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;

d) Personal data contained in the body of an email, whether sent or received, should be stored securely;

e) Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;

f) Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient or sent using a secure method of delivery;

g) All personal data transferred physically should be transferred in a suitable container marked “confidential”;

h) No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from the Company Director;

i) All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;

j) No personal data may be transferred to any employees or other parties, whether such parties are working on behalf of the Company or not, without authorisation;

k) Personal data must be handled with care at all times and should not be left unattended or on view;

l) Computers used to view personal data must always be locked before being left unattended;

m) No personal data should be stored on any mobile device, whether such device belongs to the Company or otherwise without the formal written approval of the Company Director and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary. Please refer to the Company BYOD Policy;

n) All personal data stored electronically should be backed up regularly with backups stored offsite. All backups should be encrypted;

o) All electronic copies of personal data should be stored securely using passwords and encryption;

p) All passwords used to protect personal data should be changed regularly and should be secure;

q) Under no circumstances should any passwords be written down or shared between any employees or other parties working on behalf of the Company, irrespective of seniority or department;

r) All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably and practically possible afterbecoming available; and

s) No software may be installed on any Company-owned computer or device without approval.

5.2 The following organisational measures are in place within the Company to protect the security of personal data. Please refer to the Company’s Data Protection Policy/ Employee Data Protection Policy for further details:

a) All employees or relevant other parties working on behalf of the Company can view both their individual responsibilities and the Company’s responsibilities under the GDPR in the Company’s Data Protection Policy;

b) Only employees or other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company;

c) All employees handling personal data will be appropriately trained to do so;

d) All employees handling personal data will be appropriately supervised;

e) All employees and other parties working on behalf of the Company handling personal data shall be expected and encouraged to exercise care and caution when discussing any work relating to personal data at all times;

f) Methods of collecting, holding, and processing personal data shall be regularly reviewed;

g) The performance of those working on behalf of the Company handling personal data shall be subject to review;

h) All employees or relevant other parties working on behalf of the Company handling personal data will be expected to do so in accordance with the principles of the GDPR and the Company’s Data Protection Policy;

i) All parties working on behalf of the Company handling personal data must ensure that any and all of their employees are held to the same conditions arising out of the GDPR and as contained in the Company’s Data Protection Policy;

j) Where any party working on behalf of the Company handling personal data fails in their obligations under the GDPR and/or the Company’s Data Protection Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

6. Data Disposal

6.1 Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:

6.2 Personal data stored electronically (including any and all backups thereof) shall be deleted securely;

6.3 Special category personal data stored electronically (including any and all backups thereof) shall be deleted securely;

6.4 Personal data stored in hardcopy form shall be shredded securely; and

6.5 Special category personal data stored in hardcopy form shall be shredded securely.

7. Data Retention

7.1 As stated above, and as required by law, the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.

7.2 Different types of personal data, used for different purposes, will necessarily be retained for different periods, as set out below.

7.3 When establishing and/or reviewing retention periods, the following shall be taken into account:

a) The objectives and requirements of the Company;

b) The type of personal data in question;

c) The purpose(s) for which the data in question is collected, held, and processed;

d) The Company’s legal basis for collecting, holding, and processing that data; and

e) The category or categories of data subject to whom the data relates

7.4 If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.

7.5 Notwithstanding the defined retention periods in the Appendix, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).

8. Roles and Responsibilities

8.1 The Company’s Data Protection Officer is the position holder of Company Secretary at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Herts, SG6 2TS.

8.2 The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other Data Protection-related policies (including, but not limited to, its Data Protection Policy and Employee Date Protection Policy), and with the GDPR and other applicable data protection legislation.

8.3 The Data Protection Officer and relevant colleagues, including the Company Business Development Manager for technical areas, shall be responsible for ensuring compliance with the above data retention periods.

8.4 Any questions regarding this Policy, the retention of personal data, or any other aspect of GDPR compliance should be referred to the Data Protection Officer.

9. Implementation of Policy

This Policy shall be deemed effective as of 1st June 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

V2 CKB Ltd GDPR Data Retention policy – effective date 1st June 2018

APPENDIX

Description Data Ref Personal/ Non Personal Data Data Subject Category Type of Data Purpose of Data Category Purpose of Data Detail Retention Period or Criteria

Third party customer order management system

CKB-DR-01

Personal Information

Non employee data subject

Personal data including name, address, contact details, order details and IP address

Customer Order Management

Required to process and despatch order

Indefinitely - to allow follow up of any product faults in future

Third party shopping cart provider

CKB-DR-02

Personal Information

Non employee data subject

Personal data including name, address, contact details, order details and IP address

Customer Order Management

Required to process order and store account

Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future

Third party server (customer order management)

CKB-DR-03

Personal Information

Non employee data subject

Personal data including name, address, contact details, order details and IP address

Customer Order Management

Required to store orders

Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future

Google Analytics

CKB-DR-04

Non Personal Information

Non employee data subject

Anonymised data

Digital Marketing & Analytics

Required to inform product research, marketing and advertising spend, etc

26 months

Online Advertising

CKB-DR-05

Non Personal Information

Non employee data subject

Anonymised data

Digital Marketing & Analytics

Required to inform product research, marketing and advertising spend (conversion tracking), etc

Indefinitely - anonymised data

Online Advertising

CKB-DR-06

Non Personal Information

Non employee data subject

Anonymised data

Digital Marketing & Analytics

Required to inform product research, marketing and advertising spend (conversion tracking), etc

Indefinitely - anonymised data

Third party customer service management tool

CKB-DR-07

Personal Information

Non employee data subject

Personal data including name, address, contact details, order details and IP address

CRM Customer Service

Required to communicate with customers concerning orders and answer questions concerning orders and products

Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future

Facebook

CKB-DR-08

Personal Information

Non employee data subject

Personal data including name if user interacts with posts

Social Media

Business promotion

Indefinitely - allowing for follow up of any product faults in future in the case of a comment made or competition win, for example

Twitter

CKB-DR-09

Personal Information

Non employee data subject

Personal data including name if user interacts with posts

Social Media

Business promotion

Indefinitely - allowing for follow up of any product faults in future in the case of a comment made

Instagram

CKB-DR-10

Personal Information

Non employee data subject

Personal data including name if user interacts with posts

Social Media

Business promotion

Indefinitely - allowing for follow up of any product faults in future in the case of a comment made

Pinterest

CKB-DR-11

Personal Information

Non employee data subject

Personal data including name if user interacts with posts

Social Media

Business promotion

Indefinitely - allowing for follow up of any product faults in future in the case of a comment made

Linkedin

CKB-DR-12

Personal Information

Non employee data subject

Personal data including name if user interacts with posts

Social Media

Business promotion

Indefinitely - allowing for follow up of any product faults in future in the case of a comment made

Facebook Ads

CKB-DR-13

Non Personal Information

Non employee data subject

Anonymised data

Digital Marketing & Analytics

Required to inform product research, marketing and advertising spend (conversion tracking), etc

Indefinitely - anonymised data

Twitter Ads

CKB-DR-14

Non Personal Information

Non employee data subject

Anonymised data

Digital Marketing & Analytics

Required to inform product research, marketing and advertising spend (conversion tracking), etc

Indefinitely - anonymised data

Pinterest Ads

CKB-DR-15

Non Personal Information

Non employee data subject

Anonymised data

Digital Marketing & Analytics

Required to inform product research, marketing and advertising spend (conversion tracking), etc

30 Days

Third party payment facilitator

CKB-DR-16

Personal Information

Non employee data subject

Personal data including name and total order detail

Payment Gateway

To facilitate payment being made

6 Months

Third party payment facilitator

CKB-DR-17

Personal Information

Non employee data subject

Personal data including name and total order detail

Payment Gateway

To facilitate payment being made

36 Months

Third party payment facilitator

CKB-DR-18

Personal Information

Non employee data subject

Personal data including name and total order detail

Payment Gateway

To facilitate payment being made

12 Months

Website extension tool

CKB-DR-19

Non Personal Information

Non employee data subject

Anonymised data

Website search bar history

Tool to provide insight into search history on Our Site to inform business purchasing and advertising decisions

24 Months

Third party software for location tracking for currency conversion

CKB-DR-20

Personal Information

Non employee data subject

Personal data including IP address

Currency conversion

Enhanced website functionality for better user experience

On during a users time on the website only

Third party address located based on postcode

CKB-DR-21

Personal Information

Non employee data subject

Personal data including address and IP address

Checkout Address Verification

Enhanced website functionality for better user experience

On during a users time at checkout only

Third party review company

CKB-DR-22

Personal Information

Non employee data subject

Personal data including name, transaction ID, contact details, order details and IP address

Customer Feedback & Product Reviews

Business promotion and product review/ customer service tool

Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future

Third party review company

CKB-DR-23

Personal Information

Non employee data subject

Personal data including name, transaction ID, contact details, order details and IP address

Customer Feedback & Product Reviews

Business promotion and product review/ customer service tool

Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future

Third party accountancy firm

CKB-DR-24

Personal Information

Non employee data subject and employee data subject

Personal data including name, address, contact details, order details and IP address as well as employee salary information, etc

Financial accountancy and staff payroll

Financial accountancy and staff payroll

In line with financial accounting requirements, currently 6 years

Third party electronic file share and storage system

CKB-DR-25

Personal Information

Non employee data subject and employee data subject

Personal data including name, address, contact details, order details and IP address as well as employee contract info

Business Operation

Business Operation

Reviewed in line with relevant data categories

Third party anti-virus software

CKB-DR-26

Personal Information

Employee data subject

Personal data including IP address

Business Protection

Business protection and security

Review at annual renewal time

Third party bank

CKB-DR-27

Personal Information

Non employee data subject and employee data subject

Personal data including name and IP address as well as transactional data where relevant

Business Operation

Business banking

In line with financial accounting requirements

Third party bank

CKB-DR-28

Personal Information

Non employee data subject and employee data subject

Personal data including name and IP address as well as transactional data where relevant

Business Operation

Business banking

In line with financial accounting requirements

Third party security company

CKB-DR-29

Personal Information

Employee data subject

Personal data including name and contact details for out of hours contact

Business Protection

Business protection and security

Review if a change in employee personnel/ an employee asks to be removed from contact list

Third party security company

CKB-DR-30

Personal Information

Employee data subject

Personal data including name and contact details

Business Protection

Business protection and security

Retain data for as long as there is a contractual need and also thereafter if required or permitted by law

Third party security company

CKB-DR-31

Personal Information

Employee data subject

Personal data including name and contact details for out of hours contact

Business Protection

Business protection and security

Review if a change in employee personnel/ an employee asks to be removed from contact list

Third party mailing company

CKB-DR-32

Personal Information

Non employee data subject

Personal data including name and address

Business Operation

Order delivery

Retained for as long as it needs it to carry out a particular purpose or meet a particular obligation.

 

Third party delivery company

CKB-DR-33

Personal Information

Non employee data subject

Personal data including name and address

Business Operation

Order delivery

Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future

Whats App

CKB-DR-34

Personal Information

Employee data subject

Personal data including name and contact details for out of hours contact

Business Operation

Emergency business communication

Review if a change in employee personnel/ an employee asks to be removed from contact list

Third party IT firm

CKB-DR-35

Personal Information

Non employee data subject and employee data subject

Personal data including name, address, contact details, order details and IP address

Business Operation

IT support

Review if a change in IT support company

Third party e-mail provider

CKB-DR-36

Personal Information

Non employee data subject & employee data subject

Personal data inc name,address, contact/order details/IP address & employee info

Business Operation

Communications

Reviewed in line with relevant data categories

Third party delivery company

CKB-DR-37

Personal Information

Non employee data subject

Personal data including name and address

Business Operation

Order delivery

Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future

Third party communication software

CKB-DR-38

Personal Information

Non employee data subject

Personal data including name, address, contact details, order details and IP address

Business Operation

Facilitates delivery of order confirmation e-mail

Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future

Third party accountancy firm (EU territories)

CKB-DR-39

Personal Information

Non employee data subject

Personal data including name, address, contact details, order details and IP address

Financial accountancy

Financial accountancy

In line with financial accounting requirements

Third party accountancy firm (non EU territory)

CKB-DR-40

Personal Information

Non employee data subject

Personal data including name, address, contact details, order details and IP address

Financial accountancy

Financial accountancy

In line with financial accounting requirements

Third party accountancy firm (non EU territory)

CKB-DR-41

Personal Information

Non employee data subject

Personal data including name, address, contact details, order details and IP address

Financial accountancy

Financial accountancy

In line with financial accounting requirements

Marketplace portal authorised access

CKB-DR-42

Personal Information

Employee data subject

Personal data including name, address, contact details, proof if ID

Business Operation

Marketplace portal authorised access

Review if a change in employee personnel/ job role no longer requiring portal access

Third party website developers

CKB-DR-43

Personal Information

Non employee data subject

Personal data including name, address, contact details, order details and IP address

Customer Order Management

Required to test site

Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future

Third party delivery company

CKB-DR-44

Personal Information

Non employee data subject

Personal data including name and address

Business Operation

Order delivery

Retained in line with statutory and legislative requirements

 

Third party mobile phone device and software provider

CKB-DR-45

Personal Information

Non employee data subject and employee data subject

Personal data including name, address, contact details, order details and IP address as well as employee information

Business Operation

Communications

Reviewed in line with relevant data categories

Third party cookie consent facilitator

CKB-DR-46

Personal Information

Non employee data subject

Personal data including IP address

Legal compliance

GDPR requirement

Indefinitely to provide confirmation of consent at any given time (re-consent is required every 2 months)

Third party business benefit provider

CKB-DR-47

Personal Information

Employee data subject

Personal data including name, address, contact details, and IP address

Business benefits

Financial accountancy

Retained for as long as necessary to satisfy legal, accounting and reporting requirements

Third party business benefit provider

CKB-DR-48

Personal Information

Employee data subject

Personal data including name, address, contact details and IP address

Business benefits

Financial accountancy

Max 150 years post an individual staff member's data of birth

Staff HR files

CKB-DR-49

Personal Information

Employee data subject

Personal data including name, address, contact details, emergency contact details, sickness/ health record, application and employment documentation including contracts, pay rates, training and performance reviews

Business Operation

Legal compliance

6 years after employment terminates

Job applications

CKB-DR-50

Personal Information

Non employee data subject

job application, CV, interview notes, eligibility to work documentation

Business Operation

Legal compliance

6 months after notifying unsuccessful candidates of the outcome of their application

Accident records

CKB-DR-51

Personal Information

Non employee data subject and employee data subject

Personal data including name. Sensitive data concerning accident

Business Operation

Legal compliance

6 years from the date the accident record was made

Third party online training provider

CKB-DR-52

Personal Information

Employee data subject

Personal data including name, contact details and IP address

Business Operation

Staff Training/ legal compliance

Indefinitely with active account

Third party training provider

CKB-DR-53

Personal Information

Employee data subject

Personal data including name and contact details

Business Operation

Staff Training/ legal compliance

Retained for as long as necessary to satisfy legal, accounting and reporting requirements

Third party communication provider

CKB-DR-54

Personal Information

Non employee data subject and employee data subject

Personal data including name, contact details (communication records)

Business Operation

Communications

Retained for as long as necessary to satisfy legal, accounting and reporting requirements

Third party communication provider

CKB-DR-55

Non Personal Information

Nicht angestellter Datensubjekt

Telefonnummern

Geschäftsprozess

Kommunikation

Im Einklang mit den Anforderungen der Finanzbuchhaltung