The GDPR provides individuals with a number of rights. These rights apply to processing of an individual's personal data carried out by our offices in the EEA and, in some circumstances, by our other group entities. Please see more information below on your rights and what we will require from you before we can respond to such requests.
- Right to object to direct marketing
You have the right to ask us not to process your personal data for marketing purposes, including profiling (eg. tracking your usage of our Website) to the extent that it is related to direct marketing. Within a reasonable time after receipt and consideration of your objection we will no longer process your personal data for direct marketing purposes. You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your personal data, or by contacting us at any time.
- Access to Information
The GDPR gives you the right to find out whether we are processing your personal data and, where that is the case, to receive a copy of the personal data we process and information on:
- why we are processing it;
- the categories of personal data we process about you;
- the recipients or categories of recipient to whom the personal data has been or will be disclosed;
- where possible, how long we plan to keep your personal data or the criteria we use to determine that period;
- information on your rights under the GDPR;
- information on where we received your personal data from if we did not receive it directly from you, and
- if we transfer your personal data outside of the EEA, details of the appropriate safeguards we have used to protect your personal data and uphold your personal data protection rights.
We will not charge you for complying with your request and providing you with a first copy. Any further copies may be subject to a reasonable administrative fee. Where your personal data is inseparable from the personal data of others, we reserve the right to redact or withhold it if it will infringe the rights of those third parties. We also reserve the right to withhold your personal data if permitted by relevant provisions in applicable local laws such as the UK's Data Protection Act 2018.
- The right to withdraw your consent to the processing of your personal data
If we process your personal data on the grounds of your consent, you have the right to withdraw your consent at any time. This will not affect the legality of our processing of your personal data up until the point at which you withdraw your consent. Please also note that we may still need to process your personal data on other grounds, for example to fulfil a contract with you or as required by law.
- The right to object to processing of your personal data
You have the right to object to our processing of your personal data if we are using the lawful grounds 'legitimate interest' or that the processing is in the public interest. When we receive your objection we will assess our legal grounds for processing and will stop processing the personal data if we cannot demonstrate compelling legitimate grounds to continue processing the personal data.
- The right to request the restriction of your personal data
You have the right to ask us to restrict our processing of (ie. stop using) your personal data if you think that it is inaccurate, that we are processing it illegally, or that we no longer need it for the purposes for which it was collected. While we consider your request we will stop processing your personal data within a reasonable time from the date we receive your request. We will notify you of our decision and any justifications for continuing to process your personal data as soon as we can.
- The right to request amendment or erasure of your personal data
You have the right to request the amendment of your personal data at any time if it is inaccurate. If it is incomplete, you have the right to have the information completed, taking into account the purposes of processing. You also have the right to require us to delete your personal data as soon as possible where one of the following applies:
- the personal data is no longer necessary for the purposes for which they were collected or otherwise processed;
- you withdraw your consent to us processing your personal data and we have no other legal grounds for processing it;
- the personal data has been unlawfully processed;
- the personal data must be erased for compliance with a UK or EU legal obligation on us;
- the personal data relates to a child under 16.
- The right to personal data portability
You have the right to receive personal data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those personal data to another personal data controller, if we are processing it on the grounds that you have consented to that processing or because it was necessary in order to perform a contract with you, and if we have no other legal bases for processing it. This will not apply to most of our processing of your personal data, but we mention it for completeness.
- The right to complain to the Supervisory Authority
If you feel that we have processed your personal data unfairly or unlawfully, you have the right to complain about us to the relevant Supervisory Authority, although please contact us first so that we can put things right.
- In the UK the Supervisory Authority for personal data protection is the Information Commissioner's Office. You can contact the Information Commissioner's Office here or on +44 (0)303 123 1113.
- In France the Supervisory Authority is the Commission Nationale de l'Informatique et des Libertés (CNIL), which can be contacted here or on +33 (0)153 73 2222
- In Greece the Supervisory Authority is the Hellenic personal data Protection Authority (HDPA), which can be contacted at email@example.com or on +30 210 647 5600.
- In Belgium the Supervisory Authority is the Commission for the Protection of Privacy (CPP), which can be contacted at firstname.lastname@example.org or on +32 (0)2 274 48 00.
How to exercise your rights
You can exercise your rights at any time by contacting our Global Privacy Officer, Justin Glenister, at email@example.com.
Please include in your email:
- A clear statement on which rights you are seeking to enforce;
- A full description of the information or type of information that you are writing about; and
- Details which will confirm your identity, such as a scan of your passport or driving licence and a recent utility bill.
This is so that we can keep your personal data secure and respond to you as quickly as possible. If you are asking for a large range of personal data we may ask you to be more specific, so that we can manage your request as quickly and efficiently as possible.
No fee usually required
You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Time limit to respond
We aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.