Privacy Policy

Croft Mill, Hebden Bridge

Privacy Policy / GDPR

1. Introduction

This Policy sets out the obligations of the Company regarding data protection and the rights of its members, charity contacts, funders, officers and committee members etc (“data subjects”) in respect of their personal data under the General Data Protection Regulation (“the Regulation”).

The Regulation 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.

The Company falls under the Article 30 concession as a smaller entity only processing personal data occasionally, and not in the categories that are subject to special protection. The Company considers that it falls under ICO’s exemption from registration under the DPA given at https://ico.org.uk/for-organisations/guide-to-data-protection/exemptions/

Nevertheless the Company, as a matter of good practice, aims to follow the spirit of the requirements on larger organisations. This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures and principles set out below must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company. The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance 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.

2. The Data Protection Principles

This Policy aims to ensure compliance with the Regulation. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:

a) processed lawfully, fairly, and in a transparent manner in relation to the data subject;

b) collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;

d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;

e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;

f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

PART A: Guest Privacy Notice

Croft Mill Serviced Apartments Ltd (“we”, “us”, “our”) respects your privacy. This notice explains what personal information we collect when you enquire, book or stay with us, how we use it, and your rights. We are the data controller for this information under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Who we are

Croft Mill Serviced Apartments Ltd, 19 Croft Mill Apartments, Croft Mill Yard, Hebden Bridge, HX7 8AB.
Data Protection contact: Josephine Anderson
Telephone: 01422 846836
Email: [email address]

What information we collect

When you enquire, book or stay with us, we may collect:

- your name, address, email address and telephone number

- the names of other guests in your party

- booking details, including dates of stay, apartment booked and any special requests

- payment details (card payments are processed securely by [payment provider]; we do not store full card details)

- correspondence with you, such as emails, messages and reviews

- your marketing preferences

- technical information when you visit our website, such as your IP address and browsing activity through cookies (see our Cookie Policy)

We may also receive your details from booking platforms you use to book with us, such as [Booking.com / Airbnb / other].

How we use your information

We use your information to:

- manage your enquiry and booking, and send booking confirmations and arrival information

- take payment and keep financial records

- contact you before, during or after your stay about your booking

- respond to questions, feedback or complaints

- send you news and offers by email, where you have agreed to this or have stayed with us before (you can opt out at any time)

- improve our website and services

- meet our legal and accounting obligations

Our legal reasons for using your information

We only use your information where the law allows us to:

- Contract: to take and manage your booking.

- Legal obligation: for example, to keep financial records.

- Legitimate interests: to run our business well, respond to enquiries and improve our service, where this does not override your rights.

- Consent: for marketing emails and non-essential cookies. You can withdraw consent at any time.

Marketing emails

If you agree, or if you have previously stayed with us, we may send you occasional emails about offers, events and availability. Every email includes an unsubscribe link, or you can contact us to opt out. We will never sell your details to anyone.

Who we share your information with

- We only share your information where necessary, with:

- payment providers, to process payments

- booking platforms, where you booked through them

- our email marketing provider, [provider name], to send our newsletters

- our website host and IT providers

- our accountants, and authorities such as HMRC where the law requires it

- Any third parties we use must keep your information secure and use it only for the purposes we have set.

How long we keep your information

We keep booking and financial records for [six years] to meet legal and accounting requirements. We keep marketing details until you unsubscribe. Enquiries that do not lead to a booking are deleted after [12 months].

How we protect your information

We take appropriate steps to keep your information secure, including password-protected systems, restricted access and secure storage of paper records.

Your rights

You have the right to:

- ask for a copy of the information we hold about you

- ask us to correct inaccurate information

- ask us to delete your information

- ask us to restrict or stop using your information

- object to us using your information, including for marketing

- ask for your information to be transferred to another organisation

- withdraw your consent at any time, where we rely on consent

To use any of these rights, contact us using the details above. We will respond within one month.

Complaints

If you are unhappy with how we have handled your information, please contact us first. You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk or on 0303 123 1113.

Changes to this notice

We may update this notice from time to time. The latest version will always be on our website.

PART B: Staff and Internal Data Protection Policy

1. Introduction

This Policy sets out the obligations of the Company regarding data protection and the rights of its guests, customers, employees, contractors, suppliers and directors (“data subjects”) in respect of their personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (together, “the Regulation”).

The Company [pays the ICO data protection fee, registration number: [number] / is exempt from paying the ICO data protection fee].

As a small business, the Company keeps its data protection procedures proportionate to its size and activities. This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures and principles set out below must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company. The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance 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.

2. The Data Protection Principles

This Policy aims to ensure compliance with the Regulation. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:

a) processed lawfully, fairly, and in a transparent manner in relation to the data subject;

c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;

3. Lawful, Fair, and Transparent Data Processing

The Regulation seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The Regulation states that processing of personal data shall be lawful if at least one of the following applies:

a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;

b) processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;

c) processing is necessary for compliance with a legal obligation to which the controller is subject;

d) processing is necessary to protect the vital interests of the data subject or of another natural person;

e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

4. Processed for Specified, Explicit and Legitimate Purposes

The Company collects and processes the personal data set out in Part A of this Policy (guests) and Appendix 1 (employees, contractors and directors). This may include personal data received directly from data subjects (for example, contact details used when a data subject communicates with us). The Company processes personal data for the specific purposes set out in Part A and Appendix 2 of this Policy (or for other purposes permitted by the Regulation).

5. Adequate, Relevant and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose(s) informed to data subjects under Part A and Appendix 2.

6. Accuracy of Data and Keeping Data Up To Date

The Company shall ensure that all personal data collected and processed is kept accurate and up to date. The accuracy of data shall be checked when it is collected. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

7. Timely Processing

The Company shall not keep personal data for any longer than is necessary in light of the purposes for which that data was originally collected and processed. When the data is no longer required, all reasonable steps will be taken to erase it without delay.

8. Secure Processing

The Company shall ensure that all personal data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. Further details of the data protection and organisational measures which shall be taken are provided in Sections 19 and 20 of this Policy.

9. Accountability

The Company’s Data Protection Officer is the Managing Director. Officers and employees of the Company are required to liaise with the Data Protection Officer over any matters of privacy that require judgement or where the policy here is unclear.

10. Privacy Notices and Data Protection Impact Assessments

The Company provides privacy information to guests through the Guest Privacy Notice in Part A, and to employees and contractors through this Policy and Appendix 3.

A Data Protection Impact Assessment (DPIA) is required where processing is likely to result in a high risk to individuals. The Company considers that its activities are straightforward and do not currently require a DPIA. This will be reviewed if the Company introduces new types of processing, such as CCTV or new technology that uses personal data.

11. The Rights of Data Subjects

The Regulation sets out the following rights applicable to data subjects:

a) The right to be informed;
b) The right of access;
c) The right to rectification;
d) The right to erasure (also known as the ‘right to be forgotten’);
e) The right to restrict processing;
f) The right to data portability;
g) The right to object;
h) Rights with respect to automated decision-making and profiling.

12. Keeping Data Subjects Informed

The Company shall ensure that the following information is available to data subjects when personal data is collected:

a) Details of the Company including, but not limited to, the identity of the Managing Director and its Data Protection Officer;

b) The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part A and Appendix 2 of this Policy) and the legal basis justifying that collection and processing;

c) Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;

d) Where the personal data is to be transferred to one or more third parties, details of those parties;

e) Details of the length of time the personal data will be held by the Company (or, where there is no predetermined period, details of how that length of time will be determined);

f) Details of the data subject’s rights under the Regulation;

g) Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;

h) Details of the data subject’s right to complain to the Information Commissioner’s Office (the ‘supervisory authority’ under the Regulation);

i) Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it;

j) Details of any automated decision-making that will take place using the personal data (including but not limited to profiling), including information on how decisions will be made, the significance of those decisions and any consequences.

13. Data Subject Access

13.1 A data subject may make a subject access request (“SAR”) at any time to find out more about the personal data which the Company holds about them. The Company is normally required to respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension).

13.2 All subject access requests received must be forwarded to the Company’s Data Protection Officer.

13.3 The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

14. Rectification of Personal Data

14.1 If a data subject informs the Company that personal data held by the Company is inaccurate or incomplete, requesting that it be rectified, the personal data in question shall be rectified. The data subject shall be informed of that rectification within one month of receipt of the data subject’s notice (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).

14.2 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification of that personal data.

15. Erasure of Personal Data

15.1 Data subjects may request that the Company erases the personal data it holds about them in the following circumstances:

a) it is no longer necessary for the Company to hold that personal data with respect to the purpose for which it was originally collected or processed;
b) the data subject wishes to withdraw their consent to the Company holding and processing their personal data;
c) the data subject objects to the Company holding and processing their personal data and there is no overriding legitimate interest to allow the Company to continue doing so;
d) the personal data has been processed unlawfully;
e) the personal data needs to be erased in order for the Company to comply with a particular legal obligation.

15.2 Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).

15.3 In the event that any personal data that is to be erased in response to a data subject request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

16. Restriction of Personal Data Processing

Data subjects may request that the Company ceases processing the personal data it holds about them. Unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights and freedoms, or the processing is necessary for the conduct of legal claims, the Company shall retain only the amount of personal data pertaining to that data subject that is necessary to ensure that no further processing of their personal data takes place.

17. Objections to Personal Data Processing

17.1 Data subjects have the right to object to the Company processing their personal data based on legitimate interests (including profiling), direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.

17.2 Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing forthwith, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights and freedoms, or the processing is necessary for the conduct of legal claims.

17.3 Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing forthwith.

17.4 Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Regulation, ‘demonstrate grounds relating to his or her particular situation’. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.

18. Automated Decision-Making

In the event that the Company uses personal data for the purposes of automated decision-making, data subjects have the right to challenge such decisions.

19. Data Protection Measures

The Company shall ensure that all its employees, agents, contractors, or other parties working on its behalf comply with the following when working with personal data:

a) Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hard copies should be shredded, and electronic copies should be deleted securely;

b) Personal data should be transmitted over secure networks;

c) Where personal data is to be transferred in hard copy form it should be posted or passed directly to the recipient;

d) No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from the Data Protection Officer;

e) All hard copies of personal data, along with any electronic copies stored on physical, removable media, should be stored securely in a locked box, drawer, cabinet or similar;

f) Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;

g) If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it;

h) No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Regulation (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken);

i) All personal data stored electronically should be backed up, with backups stored onsite and offsite;

j) All electronic copies of personal data should be stored securely using passwords;

k) All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised.

20. Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

a) All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;

b) Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;

c) All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so.

21. Data Breach Notification

21.1 All personal data breaches must be reported immediately to the Company’s Data Protection Officer.

21.2 If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event within 72 hours after having become aware of it.

21.3 In the event that a personal data breach is likely to result in a high risk to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.

21.4 Data breach notifications shall include the following information:

a) The categories and approximate number of data subjects concerned;
b) The categories and approximate number of personal data records concerned;
c) The name and contact details of the Company’s Data Protection Officer (or other contact point where more information can be obtained);
d) The likely consequences of the breach;
e) Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

22. Implementation of Policy

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

This Policy has been approved and authorised by:

Name: Josephine Anderson
Position: Managing Director
Date: [date]
Due for Review by: [date, e.g. one year from approval]

Croft Mill Serviced Apartments Ltd, 19 Croft Mill Apartments, Croft Mill Yard, Hebden Bridge, HX7 8AB

Appendix 1: Personal Data of Employees, Contractors and Directors

The following personal data may be collected, held, and processed by the Company.

Applications and Personnel:

- contact details, including name, address, telephone number and personal e-mail address

emergency contact details/next of kin

- date of birth

- gender

- marital status and dependants

- the start and end dates of employment or engagement

- recruitment records, including personal information included in a CV, any application form, cover letter, interview notes, references, copies of proof of right to work in the UK documentation, copies of qualification certificates, copy of driving licence and other background check documentation

- the terms and conditions of employment or engagement (including job title and working hours), as set out in a job offer letter, employment contract, written statement of employment particulars, casual worker agreement, consultancy agreement, pay review and bonus letters, statements of changes to employment or engagement terms and related correspondence

- details of skills, qualifications, experience and work history, both with previous employers and with the Company

professional memberships

- salary, entitlement to benefits and pension information

- National Insurance number

- bank account details, payroll records, tax code and tax status information

- any disciplinary, grievance and capability records, including investigation reports, collated evidence, minutes of hearings and appeal hearings, warning letters, performance improvement plans and related correspondence

- appraisals, including appraisal forms, performance reviews and ratings, targets and objectives set

training records

- annual leave and other leave records, including details of the types of and reasons for leave being taken and related correspondence

- any termination of employment or engagement documentation, including resignation letters, dismissal letters, redundancy letters, minutes of meetings, settlement agreements and related correspondence

- information obtained through electronic means, such as swipecard or clocking-in card records

- information about use of our IT systems, including usage of telephones, e-mail and the Internet

- photographs

- information about health, including any medical condition, whether you have a disability in respect of which the Company needs to make reasonable adjustments, sickness absence records (including details of the reasons for sickness absence being taken), medical reports and related correspondence

- information about racial or ethnic origin, religious or philosophical beliefs and sexual orientation

- trade union membership

information about criminal convictions and offences

Details of directors (e.g. for registration at Companies House or with banks):

contact details including name, position and personal e-mail address

other personal details as required by the registrar

Appendix 2: Purposes of Collection of Personal Data of Employees, Contractors and Directors

The purposes for which we are processing, or will process, your personal information are to:

- enable us to maintain accurate and up-to-date employee, worker and contractor records and contact details

(including details of whom to contact in the event of an emergency)

- run recruitment processes and assess suitability for employment, engagement or promotion

- comply with statutory and/or regulatory requirements and obligations, e.g. checking rights to work in the UK

- comply with the duty to make reasonable adjustments for disabled employees and workers and with other disability discrimination obligations

- maintain an accurate record of employment or engagement terms

- administer the contract we have entered into

- make decisions about pay reviews and bonuses

-ensure compliance with statutory and contractual rights

- ensure you are paid correctly and receive the correct benefits and pension entitlements, including liaising with any external benefits or pension providers or insurers

- ensure compliance with income tax requirements, e.g. deducting income tax and National Insurance contributions where applicable

- operate and maintain a record of disciplinary, grievance and capability procedures and action taken

- operate and maintain a record of performance management systems

- record and assess education, training and development activities and needs

- plan for career development and succession

- manage, plan and organise work

- enable effective workforce management

- operate and maintain a record of annual and sick leave procedures

- ascertain fitness to work

- operate and maintain a record of maternity leave, paternity leave, adoption leave, shared parental leave, parental leave and any other type of paid or unpaid leave or time off work

- pay sick pay and contractual pay entitlements, including SMP, SPP and SAP

- meet our obligations under health and safety laws

- make decisions about continued employment or engagement

- operate and maintain a record of dismissal procedures

- provide references on request for current or former employees, workers or contractors

- prevent fraud

- monitor use of our IT systems to ensure compliance with our IT-related policies

- ensure network and information security and prevent unauthorised access and modifications to systems

- ensure effective HR, personnel management and business administration, including accounting and auditing

- ensure adherence to Company rules, policies and procedures

- monitor equal opportunities

- enable us to establish, exercise or defend possible legal claims

Appendix 3: Notice to Employees and Contractors

All employees and contractors are given a copy of this Policy and are required to follow it and protect the privacy of personal information during their work with us. If you have any questions about this Policy or how we handle your personal information, please contact our Data Protection Officer:

Hayley Clayton, Croft Mill Serviced Apartments Ltd
Telephone: 01422 846836
Address: 19 Croft Mill Apartments, Croft Mill Yard, Hebden Bridge, HX7 8AB