DATA PROTECTION POLICY FOR LOGAN’S EXECUTIVE TRAVEL CUSTOMERS

• Full name of legal entity: Logan’s Executive Travel Ltd
• Data privacy manager: Office Manager
• Email address: [email protected]
• Address: 58 Galdanagh Road, Dunloy, Ballymena, BT44 9DB
• Telephone number: 028 2765 7203

We need to gather and use information or ‘data’ about you as part of our service to manage our relationship with you. We intend to comply with our legal obligations under the Data Protection Act 2018 (the ‘2018 Act’) and the EU General Data Protection Regulation (‘GDPR’) in respect of data privacy and security. We have a duty to notify you of the information contained in this policy.

This policy applies to personal data held on customers, employees, directors & suppliers of Logan’s Executive Travel Ltd.

Logan’s Executive Travel Ltd has separate policies and privacy notices in place in respect of job applicants, current and former employees, workers, volunteers, apprentices and consultants and CRB applications.

Logan’s Executive Travel Ltd has measures in place to protect the security of your data in accordance with our Data Security Policy.

Logan’s Executive Travel Ltd  will hold data in accordance with our Data Retention criteria as detailed in this policy. We will only hold data for as long as necessary for the purposes for which we collected it.

Logan’s Executive Travel Ltd is a ‘data controller’ for the purposes of your personal data. This means that we determine the purpose and means of the processing of your personal data.

This policy explains how Logan’s Executive Travel Ltd will hold and process your information. It explains your rights as a data subject.

DATA PROTECTION PRINCPLES

Personal data must be processed in accordance with six ‘Data Protection Principles.’ It must:

 be processed fairly, lawfully and transparently;

 be collected and processed only for specified, explicit and legitimate purposes;

 be adequate, relevant and limited to what is necessary for the purposes for which it is processed;

 be accurate and kept up to date. Any inaccurate data must be deleted or rectified without delay;

 not be kept for longer than is necessary for the purposes for which it is processed; and

 be processed securely.

We are accountable for these principles and must be able to show that we are compliant.

HOW WE DEFINE PERSONAL DATA

‘Personal data’ means information which relates to a living person who can be identified from that data (a ‘data subject’) on its own, or when taken together with other information which is likely to come into our possession. It does not include anonymised data.

This policy applies to all personal data whether it is stored electronically, on paper or on other materials.

This personal data might be provided to us by you, or someone else (such as an employer), or it could be created by us. We will collect and use the following types of personal data about you:

 Information supplied on your coach quotation form

 Contact details

Special Categories of Data we do not hold or process special categories of personal data. Special categories of personal data are types of personal data consisting of information as to:

 your racial or ethnic origin;

 your political opinions;

 your religious or philosophical beliefs;

 your trade union membership;

 your genetic or biometric data;

 your health;

 your sex life and sexual orientation; and

 any criminal convictions and offences.

HOW WE DEFINE PROCESSING

‘Processing’ means any operation which is performed on personal data such as:

 collection, recording, organisation, structuring or storage;

 adaption or alteration;

 retrieval, consultation or use;

 disclosure by transmission, dissemination or otherwise making available;

 alignment or combination; and

 restriction, destruction or erasure.

This includes processing personal data which forms part of a filing system and any automated processing.

HOW WILL WE PROCESS YOUR PERSONAL DATA?

Logan’s Executive Travel Ltd will process your personal data (including special categories of personal data) in accordance with our obligations under the 2018 Act.

We will use your personal data for:

 Performing the contract of coach hire between us or your group/organisation, which includes contacting you to confirm details.

EXAMPLES OF WHEN WE MIGHT PROCESS YOUR PERSONAL DATA

We have to process your personal data in various situations:

For example:

 To contact you regarding a Quotation/booking

 To provide you with invoices or other like documents

ACCESS TO YOUR PERSONAL DATA

Members of staff will have access to your personal data in order to carry out the contractual obligations Logan’s Executive Travel Ltd has to its customers/suppliers and in order to fulfil the legitimate business interests of Logan’s Executive Travel Ltd.

SUBJECT ACCESS REQUESTS

Data subjects can make a ‘subject access request’ (‘SAR’) to find out the information we hold about them. This request must be made in writing to the Office Manager.

If you would like to make a SAR in relation to your own personal data you should make this in writing to the Office Manager . We must respond within one month unless the request is complex or numerous in which case the period in which we must respond can be extended by a further two months.

There is no fee for making a SAR. However, if your request is manifestly unfounded or excessive we may charge a reasonable administrative fee or refuse to respond to your request.

YOUR DATA SUBJECT RIGHTS

You have the right to information about what personal data we process, how and on what basis as set out in this policy.

You have the right to access your own personal data by way of a subject access request (see above).

You can correct any inaccuracies in your personal data. To do you should contact the Company Secretary in writing.

You have the right to request that we erase your personal data where we were not entitled under the law to process it or it is no longer necessary to process it for the purpose it was collected. To do so you should contact the Company Secretary in writing.

While you are requesting that your personal data is corrected or erased or are contesting the lawfulness of our processing, you can apply for its use to be restricted while the application is made. To do so you should contact the Company Secretary in writing.

You have the right to object to data processing where we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop.

You have the right to object if we process your personal data for the purposes of direct marketing.

You have the right to receive a copy of your personal data and to transfer your personal data to another data controller. We will not charge for this and will in most cases aim to do this within one month.

With some exceptions, you have the right not to be subjected to automated decision-making.

You have the right to be notified of a data security breach concerning your personal data.

In most situations we will not rely on your consent as a lawful ground to process your data. If we do however request your consent to the processing of your personal data for a specific purpose, you have the right not to consent or to withdraw your consent later. To withdraw your consent, you should contact the Data Privacy Manager in writing, contact details are listed above.

You have the right to complain to the Information Commissioner. You can do this by contacting the Information Commissioner’s Office directly. Full contact details including a helpline number can be found on the Information Commissioner’s Office website (www.ico.org.uk). This website has further information on your rights and our obligations.

INTERNAL COMPLAINTS PROCEDURE

We will attempt to resolve any complaints through our internal procedure in the first instance. This is a two stage process:

 Initially the complaint will be considered by the Director of Logan’s Executive Travel Ltd within 5 working days of receiving the complaint. This will all be done by written submission.

 Should you not be satisfied with the findings of the Director a panel of two staff members of Logan’s Executive Travel Ltd will be convened to review the findings of the Director.

HOW LONG WILL WE KEEP YOUR DATA?

Logan’s Executive Travel Ltd will keep your data whilst we are entitled under law to process it, there are legitimate business interests for doing so or where it is necessary for the establishment, exercise or defence of legal claims.

The following criteria are used to determine data retention periods of personal data:

 Logan’s Executive Travel Ltd will retain your personal data for as long as you are a Customer/Supplier and for a period of 36 months after

All personal data will be disposed of confidentially and securely.

Last Updated February 2019