The way in which we are required to treat your personal data has changed, as a result of the EU General Data Protection Regulation (GDPR).
Viking Arms Ltd complies with Data Protection Legislation and is a registered ‘Data Controller’ with the Information Commissioner’s Office (ICO) – reference Z1837740.
We use your personal data primarily to provide goods and services to you, but also for related purposes, including:
- conducting checks to identify you, verify your identity and screen for financial or other sanctions
- gathering and providing information required by or relating to audits, enquiries and investigations by regulatory bodies
- complying with professional, legal and regulatory obligations that apply to our business
- ensuring business policies are adhered to, eg policies covering security and internet use
- operational reasons, such as improving efficiency, training and quality control
- ensuring the confidentiality of commercially sensitive information
- statistical analysis to help us manage our business, eg in relation to our financial performance, client base, work type or other efficiency measures
- updating customer records
- preventing unauthorised access and modifications to systems
- preparing and filing statutory returns
- ensuring safe working practices, and monitoring and managing staff absences and staff access to systems and facilities
- staff administration and assessments, monitoring staff conduct, and disciplinary matters
- marketing our goods and services
- credit reference checks via external credit reference agencies (if required)
- external audits and quality checks, eg for ISO accreditation
It would be helpful to start by explaining some key terms used in this policy:
Viking Arms Ltd
Summerbridge, Harrogate, North Yorkshire, HG3 4BW
Our data protection officer:
Any information relating to an identified or identifiable individual
Special category personal data:
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership.
Genetic and biometric data.
Data concerning health, sex life or sexual orientation.We do not currently collect any Special category Data and do not envisage the need to do so unless for future legislative or compliancy reasons.
PERSONAL DATA WE COLLECT ABOUT YOU
The information below sets out the personal data we will or may collect in the course of supplying our goods and services to you.
- Your name, address and telephone number.
- Information to enable us to check and verify your identity when applicable eg, opening a trade account. (May include your date of birth and proof of address).
- Electronic contact details, eg your email address and mobile phone number.
- Information to enable us to undertake a credit or other financial checks on you.
- Information to enable us to undertake compliancy checks when required (including consulting your local Firearms Licencing Department).
This personal data is required to enable us to provide our goods and service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing goods and services to you.
HOW YOUR PERSONAL DATA IS COLLECTED
We collect most of this information from you, direct. However, we may also collect information:
- from publicly accessible sources, eg Companies House or HM Land Registry;
- directly from a third party, eg:
- credit reference agencies;
- from a third party with your consent, eg:
- your bank or building society, another financial institution or advisor;
- via our information technology (IT) systems, eg:
- customer relationship management systems;
- automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason for doing so, eg:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. The information below explains what we use (process) your personal data for and our reasons for doing so:
|To provide goods and services to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or firearms licencing||To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, eg policies covering security and internet use||Any information relating to an identified or identifiable individual|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best goods and services for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, ie to protect our intellectual property and other commercially valuable information To comply with our legal and regulatory obligations|
|Statistical analysis to help us manage our business, eg in relation to our financial performance, client base, work type or other efficiency measures||For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best goods and services for you at the best price|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations|
|Updating customer records||For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our clients about existing and new products and services|
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best goods and services to you|
|Credit reference checks via external credit reference agencies||For our legitimate interests or a those of a third party, ie for credit control and to ensure our clients are likely to be able to pay for our goods and services|
|External audits and quality checks, eg for ISO accreditation and the audit of our accounts||For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations|
The above table does not apply to special category personal data, which we would only process with your explicit consent, should we be required to.
WHO WE SHARE YOUR PERSONAL DATA WITH
We may share personal data with:
- credit reference agencies (if credit application made);
- our insurers and brokers;
- external auditors, eg in relation to ISO accreditation and the audit of our accounts;
- our banks.
- licencing authorities
- the manufacturer of goods supplied
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We reserve the right to share some personal data with other parties. The recipient of the information will be bound by confidentiality obligations.
We will never sell your data or share it with any third party that is not directly related to the goods or services we have supplied.
WHERE YOUR PERSONAL DATA IS HELD
Information may be held at our offices and those of our service providers, representatives and agents as described above.
HOW LONG WILL YOUR PERSONAL DATA BE KEPT
We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:
to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law.
We will not retain your data for longer than necessary for the purposes set out in this policy. We generally keep data for a maximum period of 7 years.
When it is no longer necessary to retain your personal data, we will delete or anonymise it.
TRANSFERRING YOUR PERSONAL DATA OUT OF THE EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), eg:
if the manufacturer of the goods are located outside the EEA;
the licencing authorities are located outside the EEA;
if you are based outside the EEA;
These transfers are subject to special rules under European and UK data protection law. The following countries to which we may transfer personal data have been assessed by the European Commission as providing an adequate level of protection for personal data: Canada, Australia, Portugal, Tenerife, Spain.
Except for the countries listed above, these non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission or ensure that the recipient is certified with EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.
If you would like further information please contact us.
You have the following rights, which you can exercise free of charge:
|Rectification||The right to require us to correct any mistakes in your personal data|
|Restriction of processing||The right to require us to restrict processing of your personal data – in certain circumstances, eg if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations|
|To object|| The right to object: |
- at any time to your personal data being processed for direct marketing (including profiling);
- in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation. If you would like to exercise any of those rights, please: email, call or write to us; andlet us have enough information to identify you (eg your full name, address and client or matter reference number); let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and let us know what right you want to exercise and the information to which your request relates.
KEEPING YOUR PERSONAL DATA SECURE
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We are a Cyber Essentials accredited company.
HOW TO COMPLAIN
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns
HOW TO CONTACT US
Our contact details are shown below: