1. Purpose of this Policy
We understand that privacy and the security of your personal data is extremely important.
This policy describes how we collect and use personal data about you, in accordance with The Data Protection (Bailiwick of Guernsey) Law, 2017 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time as it applies to Guernsey (‘Data Protection Legislation’).
It also explains what we do to keep your information secure and where and how we collect your personal data, as well as your rights over any personal data we hold about you.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
This policy applies to any other separate and distinct legal entities that make up the RAS Group, such as RAS Group Holdings Limited, and any other businesses we add to this group in the future.
2. How we may collect your Personal Data
We obtain personal data about you, for example:
when you request a proposal from us in respect of the services we provide;
when you, your employer or our clients engages us to provide our services and also during the provision of those services;
when you contact us by email; telephone, post (for example when you have a query about our services); or
from third parties and/or publicly available resources (i.e. from your employer, the Internet, the telephone book or from Guernsey Registry).
3. The Kind of Data we hold about you
The Data we hold about you may include the following:
Your personal contact details (such as your name, address, telephone number and email address); bank account and any feedback you give to us, including by phone, email, post, or when you communicate with us via social media;
details of contact we have had with you in relation to the provision, or the proposed provision of our services;
details of any services you have received from us;
our correspondence and communications with you;
data about any complaints and enquiries you make to us;
data from research, surveys, and marketing activities;
data we receive from other sources, such as publicly available data, data provided by your employer or our clients.
identification documents such as your passport or driving licence and details of your criminal history required for Due Diligence and KYC/KYB (Know Your Customer/Know Your Business) purposes as they relate to any engagement you have with us
Your contact details and details of the emails and other electronic communications you receive from us, including whether that communication has been opened and if you have clicked on any links within that communication. We want to make sure that our communications are useful for you, so if you don’t open them or don’t click on any links in them, we know we need to improve our Services.
4.How we use Personal Data we hold about you
For the purposes necessary to complete an engagement with you, your employer or our clients and to comply with our legal and regulatory obligations;
This may include processing your personal data where you are an employee, subcontractor, supplier or customer of another client;
To help handle and answer contacts, questions, queries, complaints or disputes from you and solve any issues you have;
To notify you about any changes to our services;
To take payment from you or give you a refund;
To seek your thoughts and opinions on the services we provide or to conduct market research, either ourselves or with reputable agencies;
To help us understand the products and services you consume and the manner in which you consume them and more about your behaviour, activities, preferences, and needs, so we can serve you better and to improve existing and develop new products, services, apps and websites;
To contact you directly through mail, telephone, email, SMS services or online to provide you with information to promote, market and advertise products, services, events and activities from us and other companies that either you request from us or which we feel may be relevant and tailored to you or may interest you provided you have consented to be contacted for such purposes;
To provide for the safety, security, health and welfare of our colleagues, customers and other individuals;
To help us ensure that our customers are genuine and to prevent, investigate and detect crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
To protect us, our colleagues, customers and other individuals by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to White Rock Brewery;
To effectively handle any legal claims or regulatory enforcement actions taken against White Rock Brewery;
To manage any potential legal claims by customers;
For statistical analysis, business development and management purposes;
To fulfil our duties to our customers, colleagues, shareholders and other stakeholders;
For the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data.
Where your consent is required for the processing of your personal data, then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain data when requested, we may not be able to perform the contract we have entered into with you as we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this policy, where we are legally required or permitted to do so.
We will always retain your personal data in accordance with law and regulation and never retain your data for longer than is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
the requirements of our business and the services provided;
any statutory or legal obligations;
the purposes for which we originally collected the personal data;
the lawful grounds on which we based our processing;
the types of personal data we have collected;
the amount and categories of your personal data; and
whether the purpose of the processing could reasonably by fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
5. Data Sharing
Why might we share personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Who we might share your personal data with?
The White Rock Brewery Group
We may share your personal data with other White Rock Brewery Group Companies from time to time, so we can provide you with a high-quality service across our group.
Our service providers
We work with partners, suppliers, insurers and agencies so they can process your personal data on our behalf, but only where they meet our standards on the processing of data and security. We only share data that allows them to provide their services to us or to facilitate them providing their services to you. For example, some of our service providers may place advertising for us online, about our products and services and those of our retail partners, suppliers and third parties. As a result, where you have indicated you are happy to receive marketing from us, you might see online advertising that we have placed on the web sites you visit, or the interactive services you use. The following activities may also be carried out by third-party service providers: IT and cloud services and scanning and destruction of our client files.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
Other third parties
We may share your personal data with other third parties, for example in if we're discussing restructuring, selling or transferring part or all of a business, we may share data about you to prospective purchasers - but only so they can evaluate that business.
We may also need to share your personal data with a regulator or to otherwise comply with the law or under any code of practice by which we are bound, or we are asked to do so by a public or regulatory body;
We may need to do so in order to either exercise or protect our legal rights, users, systems and Services or in response to requests from individuals (or their representatives) seeking to protect their legal rights or the rights of others.
6. Data Security
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We take security measures to protect your data including:
Limiting physical access to our buildings to those that we believe are entitled to be there;
Implementing access controls to our IT Systems, such as firewalls, ID verification and logical segmentation and/ or physical separation of our systems and data.
7. Rights of Access, Correction, Erasure and Restriction
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal data change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
Request access to your personal data. This is sometimes called a ‘Subject Access Request’. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Request if any of the personal data we hold about you is inaccurate or out of date for us to correct it.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal data for direct marketing purposes.
Object to us processing your personal data if we are not entitled to use it any more, to have your data deleted if we are keeping it too long or have its processing restricted in certain circumstances.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
If we agree that we are obliged to provide personal data to you, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
8. Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email or write to your Relationship Manager
Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
9. Sharing Your Thoughts
When using one of our websites or mobile applications, you may be able to share data through social networks like Facebook and Twitter. For example, when you ‘like’, ‘share’ or review our Services. When doing this your personal data may be visible to the providers of those social networks, their other users and/or White Rock Brewery companies. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts so you are comfortable with how your data is used and shared on them.
10. Changes to this Policy
11. Contact Us
Please contact your Relationship Manager by email, by post or telephone if you would like to:
exercise one or more of your rights as set out above, or
you have a question or a complaint about this policy or the way your personal data is processed
You also have the right to make a complaint to the Data Protection Commissioner’s Office, the Guernsey supervisory authority for data protection issues, at any time. The Data Protection Commissioner’s contact details are as follows:
The Office of the Data Protection Commission
Guernsey Information Centre
North Esplanade, St Peter Port
Telephone: 01481 742074