Privacy Policy

Last updated 1st January 2019

1. Scope

All customer and supplier data subjects whose personal data is collected, in line with the requirements of the GDPR.

2. Responsibilities

2.1 The Data Protection Officer

GDPR Owner is responsible for ensuring that this notice is made available to data subjects prior to Cambridge Glasshouse Company Ltd, CambridgeHOK Construction Ltd & Hotbox International Ltd (CAMBHOK) collecting/processing their personal data.

2.2 Employees

All Employees of Cambridge Glasshouse Company Ltd, CambridgeHOK Construction Ltd & Hotbox International Ltd (CAMBHOK) who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and, where required, their consent to the processing of their data is secured.

3. Privacy notice

3.1 Who are we?

This Privacy Notice, issued by Cambridge Glasshouse Company Ltd, CambridgeHOK Construction Ltd and Hotbox International Ltd (collectively known as CambridgeHOK (CAMBHOK)), under the provisions of its Data Protection Policy Statement, as required under the General Data Protection Regulation (EU) 2016/679.

Our Data Protection Officer can be contacted directly here: [email protected] or 01430 449440

The personal data we would like to collect from/process on you is:

Personal data type:

• Identifying (e.g. name, address, telephone number, email address)
• Account (e.g. bank account, bank sort code, credit card details)

Source**

• New customer form, new supplier form, letter post, emails received, telephone calls
• New supplier form, telephone calls

** Where Cambridge Glasshouse Company Ltd, CambridgeHOK Construction Ltd & Hotbox International Ltd (CAMBHOK) obtained the personal data from if it has not been collected directly from you, the data subject. Personal data accessed from publicly accessible sources will be noted.

The personal data we collect will be used for the following purposes:

• To record customer orders, sales invoices, sales credit notes and payments received from customers
• To provide customers with statements showing their account history and unpaid transactions and suppliers with their account history and remittance advices.
• To provide HMRC with sample transaction data for VAT audit purposes.

Our legal basis for processing for the personal data:

• Contractual, i.e. obligations arising from our contract with you as a customer or supplier.
• Legal, i.e. obligations arising from law, e.g. data requested by HMRC as part of their audit procedures.

Any legitimate interests pursued by us, or third parties we use, are as follows:

• None

The special categories of personal data concerned are:

• None

3.2 Consent

Where consent is required, you will be asked to sign a Data Subject Consent Form GDPR_REC_4.6, in accordance with the Consent Procedure GDPR_DOC_2.7, in order that we may process your data. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by completing and signing a Data Subject Consent Withdrawal Form GDPR_REC_4.6A, in accordance with the Withdrawal of Consent Procedure GDPR_DOC_2.7A.

3.3 Disclosure

Cambridge Glasshouse Company Ltd, CambridgeHOK Construction Ltd & Hotbox International Ltd (CAMBHOK) where relevant, will pass on your personal data to third parties. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities:

• Third country (non-EU)/international organisation
• Organisation Name & geographic location
• Safeguards in place to protect your personal data

Retrieve a copy of the safeguards in place here:

• NatWest Bank UK – Data encryption – [email protected]
• Barclays Bank UK – Data encryption – [email protected]
• Barclays Merchant Services UK – Data encryption – [email protected]

3.4 Retention period

Cambridge Glasshouse Company Ltd, CambridgeHOK Construction Ltd & Hotbox International Ltd (CAMBHOK) will process personal data in accordance with the Retention of Records Procedure and will store the personal data for a period established by reference to statutory minimums and good practice and in accordance with the Retention of Records Procedure GDPR DOC 2.3.

3.5 Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that Cambridge Glasshouse Company Ltd, CambridgeHOK Construction Ltd & Hotbox International Ltd (CAMBHOK) refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

3.6 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Cambridge Glasshouse Company Ltd, CambridgeHOK Construction Ltd & Hotbox International Ltd (CAMBHOK) (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Cambridge Glasshouse Company Ltd, CambridgeHOK Construction Ltd & Hotbox International Ltd (CAMBHOK)’s data protection representatives Data Protection Officer / GDPR Owner.