This privacy notice provides you with details of how we collect, store and process your data. It should be read in conjunction with the contract that controls our business together and our general terms and conditions.
When you work with Turtle Bags your personal data will be handled in line with the requirements of the General Data Protection Regulation (GDPR) 2016.
The privacy and handling of data that identifies living individuals is important to us, we will operate a ‘by default and by design’ set of procedures to meet the requirements of the GDPR. We will be acting in the capacity of data controller and data processor. It is important that the data we hold is accurate and up to date so if any information you have provided changes then please update us using the email address shown below.
Data Controller: Turtle Bags, 3, Civic Centre, Stourport, Worcestershire. firstname.lastname@example.org, Tel 01299 827092
- Data Collected
The data we may collect, store and process includes the following types
Identity data, including but not limited to, your full name, title.
Contact data, including but not limited to, billing address, delivery / site address, email address, phone numbers.
Financial data, including but not limited to, your bank account details, transactions resulting from the work we carry out for you.
Communications data, including but not limited to, email communications
Please note that as part of our contractual relationship we may collect, store and process personal details of other individuals in your organisation and you must have obtained permission either by contract or consent with them for us to do that.
We do not collect, store or process sensitive data as defined by the regulation.
If you fail to provide data concerning yourself or others in your organisation, then we will not be able to provide the services indicated in the contract. This would result in a temporary or permanent loss of service or services and may result in additional time charges. If this happens we will notify you.
- How we collect data
Direct interaction: Data you provide to us via email, letter, phone call
From Third Parties: from accounts that you give us access to for us to manage on your behalf. The Companies House website (if your business operates as a limited company).
- How we process collected data
Your data will only be processed when there is a lawful reason to do so.
We have determined that our main lawful reasons will be:
– in order to meet the obligations of the contract that exists between us
– where we need to comply with a legal or regulatory obligation
– for our legitimate interests.
Further processing may become necessary if we need to transfer data to a third party. If this becomes necessary you will be informed of this activity.
We do not normally rely on consent as a lawful basis for processing however we will obtain it from you if a processing reason arises. Where consent has been granted it may be withdrawn at any time in writing by emailing the address shown in section 1 above.
We will only process your data under one of the lawful bases listed above.
The data provided will be held on one or more of our systems whether on premise or off premise (cloud based).
The data used for support will be stored whilst the contract is in place and for a maximum of twelve months after the contract ends. Accountancy data will be held for the statutory period as required by the UK Government.
We will process the data we hold on individuals in your organisation in order to provide the services described in the contract between our organisations.
- Your Legal Rights
Under certain circumstances, you have the right to rectification, erasure, restriction, objection, if you deem, and it is proven, the data we hold is incorrect.
You have the right to data portability
You have the right to lodge a complaint with the UK supervisory authority, which is the Information Commissioner’s Office (ICO). If you are unhappy about any aspect of how we handle your personal data or the application of your rights then please contact us in the first instance.
The ICO contact details can be found at www.ico.org.uk
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at the email address in section 1 of this document.
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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Your personal data will not be subjected to automated decision-making activities.
- Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above:
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Additional data processors as identified in paragraph 4 above.
We require all processors and third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
- International Transfers
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at the address in section 1 of this document if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- Data Security
We have put in place 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 such data. 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. This data will therefore be retained for seven years to allow us to respond to a ‘last minute’ request.
Technical data will be kept for one year beyond the date on which the last processing occurred.