Privacy policy

This policy applies to all officers and Directors of the Company. You must be familiar with this policy and comply with its terms. This policy supplements any other policies relating to internet and email use.

Who is responsible for this policy?

The responsibility for this policy rests with the Board

Our procedures

Fair and lawful processing

We must process personal data fairly and lawfully in accordance with individuals’ rights. This generally means that we should not process personal data unless the individual whose details we are processing has consented to us doing so.

The Company Secretary’s Responsibilities regarding this issue

Keeping the Board updated about data protection responsibilities, risks and issues
Reviewing all data protection procedures and policies on a regular basis  Arranging data protection guidance and advice for all Board members and those included in this policy, as necessary.
Maintaining and administering the policy
Responding to individuals such as Members and Suppliers who wish to know what data is being held on them by the Company
Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing such as IT providers, accountants, etc.
Ensuring all systems, services, software and equipment meet acceptable security standard
Approving data protection statements attached to emails, contract documents, etc as necessary

The processing of all data must be:

Necessary to deliver services to Members
In our legitimate interests and not unduly prejudice the individual's privacy
In most cases this provision will apply to routine data processing activities related to the sale and processing of hops, their testing and transport.

The Company’s Terms of Business include a Privacy Notice on data protection.

The notice:

Sets out the purposes for which we hold personal data
Highlights that our business may require us to give information to third parties.
Provides that customers have a right of access to the personal data that we hold about them

Accuracy and relevance

We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this. Individuals may ask that we correct inaccurate personal data relating to them.

Your personal data

You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required. For example, if your personal circumstances change, please inform the Company Secretary so that the data can be updated in the records.

Data security

We must keep personal data secure against loss or misuse.

Storing data securely

In cases when data is stored on printed paper, it should be kept in a secure place where unauthorised personnel cannot access it
Printed data should be shredded when it is no longer needed
Data stored on a computer should be protected by strong passwords that are changed regularly
Data stored on CDs or memory sticks must be locked away securely when they are not being used
The Company Secretary must approve any cloud service used to store data
Data should be regularly backed up inline with the company’s backup procedures
Personal data should never be saved directly to mobile devices such as laptops, tablets or smartphones
All servers containing sensitive data must be approved and protected by security software and strong firewall.

Data retention

We must not retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner consistent with our data retention guidelines.

Subject access requests

Please note that under the Data Protection Act 1998, individuals are entitled, subject to certain exceptions, to request access to information held about them. This requirement is included in the GDPR 2018 and is expected to be included in the DPA 2018 Act.

Subject access requests from Members or Officers should be referred immediately to the Company Secretary

Please contact the Company Secretary if you would like to correct or request information that we hold about you. There are also restrictions on the information to which you are entitled under applicable law. You may email contact@englishhops.com

Processing data in accordance with the individual's rights

We will abide by any request from an individual not to use their personal data for direct marketing purposes

GDPR 2018 provisions

Where not specified previously in this policy, the following provisions will be in effect on or before 25 May 2018.

Privacy Notice - transparency of data protection

Being transparent and providing accessible information to individuals about how we will use their personal data is important to the Company. The following are details on how we collect data and what we will do with it:

What information is being collected?	Full name, address, telephone and email contacts, bank account details. Crop varieties, areas and quantities. Prices. Spray records
Who is collecting it?	The Company Administrator
How is it collected?	Through the website, By direct contact with the member, customer, etc
Why is it being collected?	To enable the cooperative to conduct its business
How will it be used?	To raise invoices, pay bills, collect statistics and in other matters concerned with the conduct of day to day business.
Who will it be shared with?	As necessary and only to enable routine business to be conducted
Identity of individual responsible for policy, and general admin.	Company Secretary - Mr J F Pudge Company Administrator – Ms N Lonergan
Details of transfers to third country and safeguards	Documentation to enable sale of hops to third countries.

Consent

The data that we collect is subject to active consent by the data subject.This consent can be revoked at anytime.

Data portability

Upon request, a data subject should have the right to receive a copy of their data in a structured format. These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals.

Right to be forgotten

A data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.

Privacy by design and default

Privacy by design is an approach to projects that promote privacy and data protection compliance from the start. The Board will be responsible for conducting Privacy Impact Assessments and ensuring that all IT projects commence with a privacy plan. When relevant, and when it does not have a negative impact on the data subject, privacy settings will be set to the most private by default.

International data transfers

No data may be transferred outside of the EEA without first discussing it with the Sales Director and/or the Company Secretary. Specific consent from the data subject must be obtained prior to transferring their data outside the EEA. The lead supervisory authority is in the UK.

Data audit and register

Regular data audits to manage and mitigate risks will inform the data register. This contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant.

Reporting Breaches

All Officers have an obligation to report actual or potential data protection compliance failures. This allows us to:

Investigate the failure and take remedial steps if necessary
Maintain a register of compliance failures
Notify the Information Commissioner’s Office (ICO) of any compliance failures that are material either in their own right or as part of a Page 8 pattern of failures

Monitoring

Everyone must observe this policy. The Company Secretary has overall responsibility for this policy. He will monitor it regularly to make sure it is being adhered to.

Consequences of failing to comply

We take compliance with this policy very seriously. Failure to comply puts both you and the Company at risk. The importance of this policy means that failure to comply with any requirement may lead to disciplinary action. If you have any questions or concerns about this policy, contact the Company Secretary.