This notice has regard to the following statutory regulations:
The Data Protection Act 1998 and related statutory instruments (until 25 May 2021)
The General Data Protection Regulation (from 25 May 2020)
The Data Protection Act 2018 and related legislation (from 25 May 2018)
The Privacy and Electronic Communications Regulations 2011 (PECR) (to continue after 25 May 2018 until replaced by the ePrivacy Regulation
The Protection of Freedoms Act 2012 (biometrics and CCTV)
Scope of the Privacy Notice
This Privacy Notice is provided by Roley’s Wines Ltd, 5 trinity Crescent, London SW17 7AG (the company). The Company can be contacted on any matter relating to this Privacy Notice via the Director:
Mr R P R Short (Director)
Tel 07736 874 979
This Privacy Notice is intended to provide information about how we, the company, will use (or "process") personal data about individuals including: its staff, its current, past and prospective clients, producers, suppliers (referred to in this document as "clients").
This Privacy Notice also applies in addition to the Company’s other relevant terms and conditions and policies, including:
any contract between the Company and its staff or clients
the Company’s data protection policy
the Company's health and safety policies, including how concerns or incidents are recorded and
the staff ICT policies
Anyone who works for, or acts on behalf of, the Company (including staff, volunteers and service providers) should also be aware of and comply with this Privacy Notice, which also provides further information about how personal data about those individuals will be used.
Responsibility for data protection
Overall responsibility for data protection lies with the Company’s senior management team.
Why we need to process data
In order to carry out our ordinary duties to our clients, we need to process a small range of personal data about individuals as part of our daily operation.
Some of this activity we will need to carry out to fulfil our legal rights, duties or obligations – including those under a contract with our staff, or clients.
Other uses of personal data will be made in accordance with our legitimate interests, or the legitimate interests of another, if these are not outweighed by the impact on individuals and provided it does not involve special or sensitive types of data.
We expect that the following uses will fall within that category of our “legitimate interests”:
For the purposes of staff selection (and to confirm the identity of prospective staff)
To provide services, and monitoring clients individual needs
To maintain relationships with clients, including direct marketing or fundraising activity
For the purposes of management planning and forecasting, research and statistical analysis, including that imposed or provided for by law (such as tax, diversity or gender pay gap analysis)
To enable relevant authorities to monitor our performance and to intervene or assist with incidents as appropriate
To give and receive information and references about past, current and prospective pupils, including relating to outstanding fees or payment history, to/from any vintner type organisation and to provide references to potential employers of staff
To monitor (as appropriate) use of the Company's IT and communications systems in accordance with our ICT Policies
To make use of photographic images of clients in our publications, on our website and (where appropriate) on our social media channels in accordance with our policy on taking, storing and using images individuals
For security purposes, including CCTV
To carry out or cooperate with any company or external complaints, disciplinary or investigation process
To administer job applications and, carry out employee due diligence checks including by checking references in relation to your education and employment history
To monitor your performance in your work, including performance appraisals
To pay you or administer benefits (including pensions) in connection with your employment or other engagement with us and
Where otherwise reasonably necessary for our purposes, including to obtain appropriate professional advice and insurance for the company.
Types of personal data processed by us
This will include by way of example:
names, addresses, date of birth, telephone numbers, e-mail addresses and other contact details
car details (about those who use on-site event car parking facilities)
bank details and other financial information, e.g. about clients who pay fees to the Company past, present and prospective.
personnel files, including in connection with employment where appropriate, information about individuals' health and welfare, and contact details for their next of kin references given or received and relevant information provided by other professionals or organisations working with the Company
How we collect data
Generally, we receive personal data from the individual directly. This may be via a form, or simply in the ordinary course of interaction or communication (such as email or post)
However, in some cases personal data will be supplied by third parties (for example another company, or other professionals or authorities working with that individual) or collected from publicly available resources.
Access and sharing of personal data
Occasionally, we will need to share personal information relating to its community with third parties, such as:
professional advisers (e.g. lawyers, insurers, PR advisers and accountants, business mentor services);
government authorities (e.g. HMRC, police or the local authority);
appropriate regulatory bodies including Companies House
Accountancy in relation to payroll or HR services,
For the most part, personal data collected by us will remain within the Company, and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis).
Finally, in accordance with Data Protection Law, some of our processing activity is carried out on our behalf by third parties, such as IT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the Company’s specific directions.
How long we keep personal data
We will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason. Typically, the legal recommendation for how long to keep ordinary personnel files is up to 7 years following departure from the Company. However, incident reports and certain files will need to be kept much longer, in accordance with specific legal requirements.
If you have any specific queries about how our retention policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact:
Mr R P R Short (Director/Data Protection Officer)
Email Tel 07736 874 979
Please bear in mind that we will often have lawful and necessary reasons to hold on to some personal data even following such request. A limited and reasonable amount of information will be kept for archiving purposes, for example; and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes (called a "suppression record").
Keeping in touch and supporting Roley’s Wines Ltd
We will use the contact details of clients and other members of the wine and beverage community to keep them updated about the activities of the Company and events of interest, including by sending updates and newsletters, by email and by post. Unless the relevant individual objects, we will also:
Share personal data about clients, as appropriate, with organisations set up to help establish and maintain relationships with the community, such as the client name;
Contact clients (including via the organisations above) by post and email in order to promote and raise funds for the Company and, where appropriate, other worthy causes;
Should you wish to limit or object to any such use, or would like further information about them, please contact the Director at the address given above.
You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, we are nonetheless likely to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number).
Rights of access
Individuals have various rights under Data Protection Law to access and understand personal data about them held by us, and in some cases ask for it to be erased or amended or have it transferred to others, or for us to stop processing it – but subject to certain exemptions and limitations.
Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, or who has some other objection to how their personal data is used, should put their request in writing to the Data Protection Officer at the address given above.
We will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits (which is one month in the case of requests for access to information).
We will be better able to respond quickly to smaller, targeted requests for information. If the request for information is manifestly excessive or similar to previous requests, we may ask you to reconsider, or require a proportionate fee (but only where Data Protection Law allows it).
Requests that cannot be fulfilled
You should be aware that the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals or information which is subject to legal privilege (for example legal advice given to or sought by the Company, or documents prepared in connection with a legal action).
You may have heard of the "right to be forgotten". However, we will sometimes have compelling reasons to refuse specific requests to amend, delete or stop processing your (or your child's) personal data: for example, a legal requirement, or where it falls within a legitimate interest identified in this Privacy Notice. All such requests will be considered on their own merits.
Where we are relying on consent as a means to process personal data, any person may withdraw this consent at any time (subject to similar age considerations as above). Examples where we do rely on consent are: e.g. biometrics, certain types of uses of images, certain types of fundraising activity. Please be aware however that we may not be relying on consent but have another lawful reason to process the personal data in question even without your consent.
That reason will usually have been asserted under this Privacy Notice, or may otherwise exist under some form of contract or agreement with the individual (e.g. an employment or parent contract, or because a purchase of goods, services or membership of an organisation such as an alumni or parents' association has been requested).
The rights under Data Protection Law belong to the individual to whom the data relates.
Where a client seeks to raise concerns confidentially with a member of staff and expressly withholds their agreement to their personal data being disclosed to another ‘involved’ party, we may be under an obligation to maintain confidentiality unless, in our opinion, there is a good reason to do otherwise; for example where we believe disclosure will be in the best interests of the client or staff member, or if required by law.
Clients are required to respect the personal data and privacy of others, and to comply with the Company's ICT policy and the Company rules. Staff are under professional duties to do the same covered under the staff ICT and taking, storing and using images of clients policies.
Data accuracy and security
We will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. Individuals must please notify the Director of any significant changes to important information, such as contact details, held about them:
Mr R P R Short (Registrar) Email Tel 07736 874 979
An individual has the right to request that any out-of-date, irrelevant or inaccurate or information about them is erased or corrected (subject to certain exemptions and limitations under Data Protection Law): please see above for details of why we may need to process your data, of who you may contact if you disagree.
We will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to Company systems. All staff will be made aware of this policy and their duties under Data Protection Law. Staff will receive relevant training.
The Company will update this Privacy Notice from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.
Queries and complaints
Any comments or queries on this policy should be directed to the Data Protection Officer at the address detailed above.
If an individual believes that we have not complied with this Privacy Notice or have acted otherwise than in accordance with Data Protection Law, they should contact.
Mr R P R Short (Director/Data Protection Officer)
Email Tel 07736 874 979
You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with the Company before involving the regulator.