1. INTRODUCTION AND TERMS
2. WHO WE ARE AND HOW TO CONTACT US
3.1.1. The right to be informed– We must make available this privacy notice with the emphasis on transparency over how we process your data.
3.1.2. The right of access– You are entitled to find out what details we may hold about you and why.
3.1.3. The right to rectification– We are obliged to correct or update your details.
3.1.4. The right to erasure– This is also known as the request to be forgotten.
3.1.5. The right to restrict processing– You have the right to ‘block’ or suppress the processing by us of your personal data.
3.1.6. The right to data portability– You have the right to obtain and reuse your personal data that you have provided to us.
3.1.7. The right to object– You have the right to object to us processing your data in relation to direct marketing and or profiling.
3.1.8. Rights in relation to automated decision making and profiling– We do not use automatic decision making or processing.
4. THE DATA WE COLLECT ABOUT YOU
4.1. We process both Personal and Sensitive (Special) categories of data. Personal data we process may include name, address and email address. It also may include IP address and cookies (Website). Due to the nature of our business we also process Sensitive (Special) categories of data, such as health data, racial or ethnical origin and biometric data (passports for identification and verification purposes as required by law).
4.2. Our collection methods are:
4.2.1. Through our website
4.2.2. Through engagement of our services
4.2.3. By communications
4.2.5. Through engagement of service providers
5. HOW YOUR DATA WILL BE USED
5.1. We use information held about you to:
5.1.1. ensure that content from our site is presented in the most effective manner for you and for your devices;
5.1.2. provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes or by Legitimate Interests*;
5.1.3. carry out our obligations arising from any contracts entered into between you and us;
5.1.4. allow you to participate in interactive features of our service when you choose to do so, e.g. asking a question through our website.
5.1.5. carry out necessary maintenance to our infrastructure; and
5.1.6. notify you about changes to our services
5.2. We also embrace the use of social media and may wish to process any comments made public by you.
6. LEGITIMATE INTEREST & MARKETING
6.1. Where we use Legitimate Interests we will record our decision and our method on making this decision. This can be requested by you at any time.
6.2. If you are an existing contact or customer we will only contact you by postal and electronic means (e-mail) with information about services or goods which you have previously purchased from us or enquired about. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by post or electronic means only if you have consented to this. You can choose to not receive these types of communication by contacting us.
7. THIRD PARTIES
7.1. We will keep your information within XLR except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you. We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
7.2. Please see below the list of services where we use third party data processors which sets out the categories of recipients of personal data.
|IT Provider – Cloud Service – IT Support
|Secure document disposal service
|Internal HR systems provider
|Marketing delivery service
|Cleaning service (Offices)
|External HR / Payroll provider
|Passenger Information software
|Life Insurance providers
|Occupational Health Assessors
|Aviation Medical Examiners
|Car Registration recognition / parking
8. DATA RETENTION
Our data retention policy is dictated by the DPA/GDPR and is available for inspection by submitting a written request using the contact details provided in this policy.
9. DATA DELETION
Under GDPR you have the right to erasure under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and must be submitted in writing to the contact details provided in this policy.
10. DATA CORRECTION
We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.
11. DATA INSPECTION
11.1. We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their personal data by making a ‘subject access request’ under the DPA and ‘Right of access’ under the GDPR. Such requests must be in writing to the contact details provided in this policy. If we do hold your personal data we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy).
11.2. The information we supply will:
11.2.1. Confirm that your data is being processed;
11.2.2. Verify the lawfulness and the purpose of the processing;
11.2.3. Confirm the categories of personal data being processed;
11.2.4. Confirm the type of recipient to whom the personal data have been or will be disclosed, and
11.2.5. Let you have a copy of the data in an intelligible form.
11.3. Please note that you may need to provide identification in order to prove who you are to access your data.
11.4. If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
11.5. In the instance that we do not hold information about you we will also confirm this in writing at the earliest opportunity.
We keep our privacy notice under regular review and you should check back regularly to ensure you are aware of changes to it. We may display this notice to you from time to time to help ensure you are aware of its contents.
You have the right to complain about the processing of your personal data. Please contact us using the details provided above. If you are still unsatisfied you have the right to complain to the Information Commissioners Office.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
WE USE THE FOLLOWING COOKIES:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
|Provide fonts for web browsers
|Content Deliver Network – provides optimised web application delivery
|Embedded Google Maps
You may block cookies by activating the setting on your browser that allows you to refuse the storage of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
14. OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in out supply chains.
As part of our initiative to identify and mitigate risk we have in place systems to:
• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.
SUPPLIER ADHERENCE TO OUR VALUES
XLR is communicating its Anti-Slavery Policy and expectations to its suppliers and business partners and will keep its supply chain arrangements under continuous review to ensure that its anti-slavery position is upheld. The group also intends to keep its policy and arrangements under continuous review to ensure that these remain adequate and effective in enabling all of the above companies to play their part in eradicating modern slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending April 2020.