PRIVACY NOTICE FOR CATERHAM PUBLISHING LTD. CUSTOMERS AND PROSPECTIVE CUSTOMERS

This notice applies to you if you are an individual customer (including a sole trader or partnership) of ours or an employee of our corporate customer or group company of our corporate customer, who (i) has contracted with us to purchase our services/products; or (ii) we have contacted you about the services/products we offer as a business. This notice does not form part of any contract to provide services/products. References to we, our or us in this privacy notice are to Caterham Publishing Ltd. (trading as The Caterham and District Independent and The Warlingham and District Independent) of The Officers’ Mess, Coldstream Road, Caterham, Surrey CR3 5QX.  For the purposes of this notice Caterham Publishing Ltd. will be the controller of any of your personal information. We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, however, we have appointed a member of personnel to be responsible for overseeing our compliance with data protection laws. Contact details are set out in the "Contacting us" section at the end of this privacy notice. We are committed to respecting your privacy. This notice is to explain how we may use the personal information we collect and use about you during and after your working relationship with us. This notice also explains how we comply with the law on data protection and what your rights are.

1.    PERSONAL INFORMATION WE COLLECT

When you interact with us or we interact with you in relation to our products and services, you may provide us with or we may obtain personal information about you, such as the following: 

• ·      Contact details: information that allows us to contact you directly such as your name, email address, telephone numbers, address, details of availability.
• ·      Purchase details and requirements: details of the products or services you have asked us to provide to you, or other instructions and decisions made by you in relation to our products or services;
• ·      Financial information: bank accounts, payment and receipt details, refund or credit details and details of payment transactions with you;
• ·      Records of your interactions with us: such as any enquiries or complaints you make, telephone conversations, letters and other correspondence (including e-mail and SMS). 

2.    SPECIAL CATEGORIES OF PERSONAL INFORMATION

We will not collect, store and use the following “special categories” of more sensitive personal information regarding you:

• ·      information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
• ·      information about your trade union memberships;
• ·      information about your health, including any medical condition, health and sickness records, medical records and health professional information and disability information; and
• ·      biometric information about you, for example fingerprints, retina scans. If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information. We will also not collect, store and use any criminal records information in relation to you.  

3.WHERE WE COLLECT YOUR INFORMATION

We will collect personal information from a number of sources. These include the following:

• ·      Directly from you: from yourself or the company you work for, when you make a request to use our services, make a complaint, contact us by phone, email or communicate with us directly in some other way.
• ·      Third parties authorised by you: a family member or someone else authorised by you.
• ·      If you are providing information regarding other individuals to us, it is your responsibility to ensure that you have the right to provide the information to us. If you are providing us with details about other individuals they have a right to know and to be aware of what personal information we hold about them, how we collect it and how we use and may share that information.

4. WHAT WE USE YOUR PERSONAL INFORMATION FOR

Your personal information is used for such purposes as: 

• ·      Contacting you in relation to providing you with our services;
• ·      Notifying you of deadlines for advertising in The Caterham and District Independent and The Warlingham and District Independent;
• ·      Notifying you of stories coming up in future editions of The Caterham and District Independent and The Warlingham and District Independent;
• ·      Notifying you of special promotions we may run from time to time;
• ·      Invoicing you for providing you with our services.

For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or comply with legal obligations. For other personal information, whilst you may not be under an obligation to provide it to us, if you do not provide it then we may not be able to properly perform our services for you. You should be aware that it is not a condition of any contract with us that you agree to any request for consent from us and we do not usually rely on consent as a basis for processing your personal information. However, if we have asked you for consent, and you have given us your consent to use  your personal information, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the "Contacting us" section below. Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent.

Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide/ carry out certain activities.

5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We may share personal information with the following parties:

• ·      Any party approved by you: for example, family members.
• ·      Credit reference agencies.
• ·      Other service providers to our business and advisors: third party banks, administration and IT services and other service providers. All our third-party service providers are required to take appropriate security measures to protect your personal information.
• ·      IT services and other service providers. All our third-party service providers are required to take appropriate security measures to protect your personal information.
• ·      Advisors: either advisors appointed by you, for example, legal advisors or advisors appointed by us. Purchasers of our business: buyers or perspective buyers to whom we may sell or negotiate to sell our business.
• ·      Sub-contractors: such as our couriers, bookkeeper, accountant, graphic designer;
• ·      The Government, government bodies or our regulators: where we are required to do so by law or to assist with their investigations or initiatives, for example HMRC or the Information Commissioner’s Office.
• ·      Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
• ·      We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell, rent or trade your data.

6.  HOW LONG DO WE KEEP PERSONAL INFORMATION FOR

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of approximately six years following the end of our customer relationship with you or the organisation you work for, because this is the limitation period for claims related to breach of contract. The exceptions to this general rule are: Where you or the organisation you work for have not yet become a customer and we are only engaged in marketing to you, we will retain your details for a period of three years since our last interaction, unless you or the organisation you work for later become a customer; It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move home or change your phone number or email address. You can contact us by using the details set out in the "Contacting us" section below.

7. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

You have the following rights in relation to your personal information:

• ·      the right to be informed about how your personal information is being used;
• ·      the right to access the personal information we hold about you;
• ·      the right to request the correction of inaccurate personal information we hold about you;
• ·      the right to request the erasure of your personal information in certain limited circumstances;
• ·      the right to restrict processing of your personal information where certain requirements are met;
• ·      the right to object to the processing of your personal information;
• ·      the right to request that we transfer elements of your data either to you or another service provider; and
• ·      the right to object to certain automated decision-making processes using your personal information.
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You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal data. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights. Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/. To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contacting us" section below. If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

8. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

9. CONTACTING US In the event of any query or complaint in connection with the information we hold about you, please email This email address is being protected from spambots. You need JavaScript enabled to view it. or write to us at Caterham Publishing Ltd., The Officers’ Mess, Coldstream Road, Caterham CR3 5QX.

Version dated 23 May 2018