This policy applies to any personal data we collect about you when you:
- use any of our websites set out in section 9 below;
- use any of our apps;
- contact us or when we contact you;
- apply for one of our vacancies;
- purchase goods or services from us;
- provide services or goods to us (where, for example, you are a sole trader, partnership or where you are providing services or goods on behalf of your employer/contractor); and/or
- visit our sites.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The full details of Smiths Concrete Ltd as data controller are set out at the end of this policy.
If you have any questions, comments or requests regarding our data processing practices, please use the "Contact Us" page on our websites.
1 INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information about you in the following circumstances:
- 1.1 Information you give us: This is information about you that you give to us by filling in forms on our websites or our apps, or by corresponding with us by phone, face-to-face, e-mail or otherwise. This includes information that you provide when you send an enquiry via our websites, register to receive updates or access our online library, register to use our apps, register for our Academy, use our interactive "tech-talk" feature, sign up to receive our company newsletter, place an order for our goods and/or services, enter any of our promotions or competitions, report issues or complaints to us, submit job applications or your CV to us (including completing psychometric tests), when you sign in at reception on one of our sites and/or when you provide us with contact details or other details in respect of any goods and/or services you may be providing to Smiths Concrete. The information you give us may include your name, address, date of birth, e-mail address, phone number, user-name and password, details of any comments or feedback that you provide to us, and financial and credit card information. Other information you give us may include feedback regarding our services, our websites, our apps, or our sites, and responses to surveys and/or market research (although you do not have to respond to such surveys or requests). We may also collect and process records of any correspondence and communications with us in whatever format you send these to us. Inbound and outbound telephone calls may also be recorded.
- 1.2 Information we collect about you: We may collect the following information about you:
- 1.2.2 information about your visits to our sites, including CCTV images;
- 1.2.3 information about your calls to our contact centre, including a recording of such call and information about your orders for goods or services;
- 1.2.4 information about services or goods that you provide to us including, for example, in connection with accidents or incidents as part of the service delivery;
- 1.2.5 information about your buying habits and patterns when you purchase goods from us.
- 1.3 Information we receive from other sources: We may receive information about you from other sources including when we use third party providers to assist us with financial verification checks when you are seeking to open a credit account with us and/or from third party vendors if we use customer lists from such third parties and from other third parties who work with us in connection with our goods or services. We also receive information from third party registers of suppliers where it is a condition of our contract with your employer (for example, to ensure that our supplier has appropriate insurance) when you are involved in the provision of goods or services to us. Third-party service providers may, without limitation, be appointed to run survey campaigns. We may also receive information about you where we request references (for example, where you are applying for a vacancy with Hanson).
- 1.4 Call recording and call monitoring: Please note that telephone calls into and out of our contact centres are recorded and may also be monitored live for the purposes of training and verifying your order. We record and monitor telephone calls where this is necessary for entering into a contract, or negotiating a contract, with you, or for our legitimate business interests, as detailed further below. Call recordings are retained for up to 6 years for evidential purposes.
- 1.5 CCTV and photographs/image recording: Please note that CCTV and other image capturing devices are used across our sites and that your image may be captured by CCTV when you visit one of our sites. Some of our vehicles also use dashboard CCTV devices and your image may also be captured when you come into contact with one of our vehicles. We may also take photographs or record images of visitors to our sites on our site open days for publicity purposes. You have the right to object to having your photograph or image taken, at any time.
- 2 WHERE WE STORE YOUR INFORMATION
- 2.1 All information you provide to us is stored on our secure servers, or those of our group, within the European Economic Area ("EEA").
- 2.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites and apps, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
- 2.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, including keeping security patches up to date wherever possible, and by constantly investigating new ways to keep data secure.
- 3 HOW WE USE YOUR INFORMATION
- 3.1 We use information held about you in the following ways:
- 3.1.1 to provide you with information that you request from us or which we feel may interest you. We may, on occasion and, where appropriate where you have consented, send you marketing information by email or post. This can include notifications about the launch of new goods, competitions, offers or other relevant news articles that you might find interesting. If you would like to stop receiving such information from us, please click on the "unsubscribe" link in any such emails that we send to you, or use the contact details at the beginning of this policy;
- 3.1.2 to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, goods and services that you request from us including in setting up credit accounts, in relation to our rights under any such contracts and also to contact you via phone calls, text messages or emails regarding the goods we are delivering to you and the progress of your delivery;
- 3.1.3 in the case of call recordings, to train our staff, monitor staff performance and verify your order, for our legitimate business interests;
- 3.1.4 to allow you to participate in interactive features on our websites, our apps, and in relation to our services, when you choose to do so;
- 3.1.5 to notify you about changes to our services and goods;
- 3.1.6 to provide customer support;
- 3.1.7 to ensure that content from our websites and our apps is presented in the most effective manner for you and for your computer;
- 3.1.8 to review your CV and suitability for a role;
- 3.1.9 to manage the services/goods that you are delivering to Hanson, for example to sign you in when you visit our site or to manage the goods you are delivering for Hanson, for example if you are a haulier and delivering our goods on our behalf to our customers (in which case, your name will appear on our delivery tickets);
- 3.1.10 to allow us to open a credit account for you (for example, by running financial and security checks (in particular in relation to trade sanctions));
- 3.1.11 to administer our websites and our apps and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- 3.1.12 to improve our websites and our apps to ensure that content is presented in the most effective manner for you and for your computer;
- 3.1.13 to enhance our websites and our apps, and the customer service experience generally (for example, through call recording) to ensure you receive a personalised and continuously improving customer service;
- 3.1.14 to improve our processes and procedures, including training of our staff to improve our service to you;
- 3.1.15 to allow you to participate in interactive features of our websites and our apps, when you choose to do so;
- 3.1.16 as part of our efforts to keep our sites and vehicles safe and secure and to improve our processes (for example, through the use of CCTV, dashboard CCTV and any other relevant image recording, and through incident reporting);
- 3.1.17 to analyse your spending and buying habits when purchasing goods from us to improve our own goods and services;
- 3.1.18 to measure, understand or monitor the effectiveness of advertising, promotions, marketing material and content and any joint initiatives with our affiliates, suppliers, partners, subcontractors and other selected third parties;
- 3.1.19 to make suggestions and recommendations to you and other users of our websites and our apps or services about goods or services that may interest you or them;
- 3.1.20 to comply with our legal and regulatory obligations and for the purposes of assisting with the prevention and detection of crime; and
- 3.1.21 to demonstrate and publicise our commitment to local communities and the environment by inviting local residents to visit our site open days and publishing photographs or releasing images of these events.
- 4 USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS
- 4.1.1 Compliance with legal obligations: We may need to process your personal data to comply with our regulatory and statutory obligations, for example when you enter our sites in the context of health and safety, or where required to assist with the prevention and detection of crime. Failure to provide the requisite personal information on sign-in at one of our sites will unfortunately mean that you will be unable to remain on the relevant site, as we must have clarity over who is on our sites at any one time. You will not be able to object to this processing or ask for the deletion of your personal information insofar as it falls under this category.
- 4.1.2 Necessary for the entry into / performance of a contract: When you enter into a transaction with us, a contract between you and us will have been entered into. In order for us to fulfil our obligations under such contract (e.g. to allow you to place an order for goods), we will need to collect, process and share (as further detailed below) your personal information. Failure to provide the requisite personal information when placing your order and financial information on entering into the transaction or objecting to this type of processing / exercising your deletion rights will unfortunately mean we cannot provide our goods and/or services to you.
- 4.1.3 Consent: We may, on occasion, send you marketing messages by email and post about us and our events and offers where you have not unsubscribed and where you have purchased goods or services from us, or where you have otherwise consented.
If you are not a customer of ours but have provided us with consent to use your details for marketing purposes, then we may also contact you about our events, goods and services.
In each of the situations above, you have the right to withdraw your consent at any time and can object to processing of this nature.
We have a legitimate interest in processing your information as:
Impact of processing
We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as the processing of your personal data does not unreasonably intrude on your privacy.
- 5 HOW LONG WE KEEP YOUR INFORMATION FOR
- 5.1 When your data is no longer required for the purposes listed above, we will delete it within the periods set out below:
- 5.1.1 Marketing emails and other communications where possible will typically be deleted after 24 months, unless we are required for legal and regulatory purposes to retain such communications for a longer period;
- 5.1.2 Call recordings with customers, suppliers and other third parties will typically be deleted after 6 years;
- 5.1.3 CCTV will typically be deleted after 60 days;
- 5.1.4 Job applications, including CVs, interview notes, and psychometric test results, which have not resulted in a role with Smiths on this occasion will typically be deleted within 6 months;
- 5.1.5 Photographs and images from our site open days will typically be deleted and not used further after 2 years;
- 5.1.6 Any other information will typically be deleted after 6 years from the date of our last positive interaction with you or sooner wherever possible. Data will be archived at appropriate intervals depending on the type of information and the frequency of our interactions with you.
- 5.2 We may keep your personal information for up to 6 years, to enable us to retain the information we may require for legal and regulatory purposes. Some information, for example information relating to health and safety, may be kept for up to 40 years.
- 6 DISCLOSURE OF YOUR INFORMATION
- 6.1 We may disclose your personal information:
- 6.1.1 to business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, for example where we use a third party to provide services to enable us to deliver goods and/or services to you;
- 6.1.2 to credit reference companies for the purposes of running credit checks (specifically Dunn & Bradstreet and Experian);
- 6.1.3 to members of the our group and third party suppliers and service providers for the purposes listed under section 3 above, for example where we use a third party to provide services to enable us to deliver goods and/or services to you or where we share IT platforms or processes with our group;
- 6.1.4 to our customers, where you are an external haulier delivering our goods to our customers (in which case we may disclose your name to the relevant customer for the purposes of managing the delivery);
- 6.1.5 to analytics and search engine providers and other selected third parties that assist us in the improvement and optimisation of our websites and our apps;
- 6.1.6 to our regulators, law enforcement or fraud prevention agencies, as well as our advisors (including legal advisors and auditors), courts, any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters etc;
- 6.1.7 to the public generally, if we publish your photograph or use your image on our website for publicity purposes or to demonstrate our commitment to local communities and the environment. We may also use such images in our marketing brochures and therefore disclose your image to any of our customers who receive such brochures;
- 6.1.8 in the event of a merger, acquisition or other similar event, to a prospective buyer or otherwise of our business or assets, in which case we will disclose your personal data to such prospective buyer or otherwise of such business or assets;
- 6.1.10 to legal advisors and otherwise in connection with legal proceedings in order to enforce or apply our rights under any contract.
- 7 YOUR RIGHTS
- 7.1 You have a number of rights under data protection law in relation to the way we process your personal data. These are set out below. You may contact us using the details on our websites (or by contacting our Data Protection Manager directly – details above) to exercise any of these rights, and we will respond to any request received from you within one month from the date of the request.
DESCRIPTION OF RIGHT
(1) A right to access personal data held by us about you.
(2) A right to require us to rectify any inaccurate personal data held by us about you.
(3) A right to require us to erase personal data held by us about you. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with your right to object as set out below).
(4) A right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims.
(5) A right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation, at your request.
(6) A right to object to our processing of personal data held by us about you where the processing of such data is necessary for the purposes of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights or which are for the establishment, exercise or defence of legal claims.
(7) A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you.
(8) A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or goods).
- 7.2 If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office. Their address is:
- 7.3 Our websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
First Contact Team
Information Commissioner's Office
- 8 DETAILS OF THE DATA CONTROLLER
For the purpose of applicable data protection legislation, the data controller is Smiths Concrete Limited : with registered office at Enslow, Kidlington. Oxford, Oxfordshire, OX5 3AY United Kingdom.
- 9 OUR WEBSITES
- 9.1 This policy applies to the following website: [www.smithsconcrete.co.uk]
- 10.2 This policy was last reviewed and updated: July 2018