COOKIES AND PRIVACY
Welcome to Navigator MSL Limited’s privacy notice.
Navigator MSL Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data which you provide to us when you enter into a contract with us to purchase a product or service (whether on behalf of an organisation or personally), make payment to us, make an enquiry to us, visit our website at www.navigatormsl.com (regardless of where you visit it from) or otherwise. This privacy notice will also tell you about your privacy rights and how the law protects you. In case of conflict, this privacy notice shall prevail over any contract with us to purchase a product or service.
Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- Important information and who we are.
Purpose of this privacy notice: This privacy notice aims to give you information on how Navigator MSL Limited collects and processes your personal data which you provide to us when you enter into a contract with us to purchase a product or service (whether on behalf of an organisation or personally), make payment to us, make an enquiry to us, visit our website (regardless of where you visit it from) or otherwise. We do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Navigator MSL Limited is the controller and is responsible for your personal data (collectively referred to as the “Company”, “we”, “us” or “our” in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details - Our full details are:
Navigator MSL Limited – for the attention of the data privacy manager
Mill Road, Sharnbrook, Bedford, MK44 1NP
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in April 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links on our website
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and systems.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data:
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
- How is your personal data collected?
We may use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account with us (on our website or otherwise);
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. For example, we may sometimes collect additional information from third parties including credit reference agencies or other background check agencies.
We may also record phone conversations we have with you.
- How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer or contact
Performance of a contract with you or a third party
To process and deliver your order/instructions including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, offers and other information (such as in respect of events we may run or news updates we may provide) may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us, purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have opted-in to receive that marketing and have not subsequently opted out of receiving that marketing.
We will also get your express opt-in consent before we share your personal data with any company outside the Company (or our group) for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
A cookie is a piece of information stored on your computer’s hard drive that records how you have used a website. The next time you visit that website, it can tailor your options based on the information it has stored about your last visit.
Further information can be found at https://ico.org.uk/for-the-public/online/cookies.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We would not allow any third-party service providers to us to use your personal data for their own purposes and would only permit them to process your personal data for specified purposes and in accordance with our instructions.
- International transfers
We do not knowingly transfer your personal data outside the European Economic Area (“EEA”). However, some External Third Parties may run their operations outside of the EEA. Although they may not be subject to the same data protection laws as organisations based in the UK, we will take steps to make sure they provide an adequate level of protection in accordance with UK data protection law. By submitting your personal information to us you agree to this transfer, storing or processing at a location outside of the EEA.
- Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available from us by request. Please be aware that, by law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data. Please see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are explained in the Glossary.
If you wish to exercise any of these rights, please contact us.
No fee usually required
You will not 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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you, an organisation you represent or a third party are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
Other companies in the Company’s group, acting as joint controllers or processors.
External Third Parties include:
• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, accountants/auditors, marketing advisers, human resources advisers and insurers who provide consultancy, banking, legal, marketing, human resources, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
We hold personal data about our employees, customers, suppliers and other individuals for a variety of business purposes.
This policy sets out how we seek to protect personal data and ensure that all staff understand the rules governing their use of personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Compliance Officer (DCO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.
|Business purposes||The purposes for which personal data may be used by us:|
Personnel, administrative, financial, regulatory, payroll and business development purposes.
Business purposes include the following:
– Compliance with our legal, regulatory and corporate governance obligations and good practice
– Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
– Ensuring business policies are adhered to (such as policies covering email and internet use)
– Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security and checking
– Investigating complaints
– Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments
– Monitoring staff conduct, disciplinary matters
– Marketing our business
– Improving services
|Personal data||Information relating to identifiable individuals, such as job applicants, current and former employees, agency, contract and other staff, clients, suppliers and marketing contacts.|
Personal data we gather may include: individuals’ contact details, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.
|Special categories of personal data||Personal data about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings—any use of special categories of personal data should be strictly controlled in accordance with this policy.|
This policy applies to all staff. You must be familiar with this policy and comply with its terms.
This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.
As our Data Compliance Officer, Alison Saunders has overall responsibility for the day-to-day implementation of this policy.
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 this happening or we are otherwise lawfully permitted to process the personal data.
The Data Compliance Officer’s responsibilities:
- Keeping the board updated about data protection responsibilities, risks and issues
- Reviewing all data protection procedures and policies on a regular basis
- Give data protection advice to all staff members and those included in this policy
- Answering questions on data protection from staff, board members and other associated parties
- Responding to individuals such as customers and employees who wish to know which data is being held on them by Navigator MSL Ltd & Midbrass Limited
- Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing
- Ensure all systems, services, software and equipment meet acceptable security standards
- Checking and scanning security hardware and software regularly to ensure it is functioning properly
- Researching third-party services, such as cloud services the company is considering using to store or process data
- Approving data protection statements attached to emails and other marketing copy
- Addressing data protection queries from customers, target audiences or media outlets
- Co-ordinating with the DCO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy
- Necessary to deliver our services
- In our legitimate interests and not unduly prejudice the individual’s privacy
- In most cases this provision will apply to routine business data processing activities
- Sets out the purposes for which we hold personal data on customers
- Highlights that our work may require us to give information to third parties such as expert witnesses and other professional advisers
- Provides that customers have a right of access to the personal data that we hold about them
In most cases where we process special categories of personal data we will require the data subject’s explicit consent to do this unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.
- Accuracy and relevance
Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DCO, Alison Saunders.
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 Data Compliance Officer so that they can update your records.
You must keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DCO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third party organisations.
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 DCO must approve any cloud used to store data.
- Servers containing personal data must be kept in a secure location, away from general office space.
- Data should be regularly backed up in line with the company’s backup procedures.
- Data should never be saved directly to mobile devices such as laptops, tablets or smartphones.
- All servers containing special categories of personal data must be approved and protected by security software and strong firewall.
We must 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.
Transferring data internationally
There are restrictions on international transfers of personal data. You must not transfer personal data anywhere outside the UK without first consulting the Data Compliance Officer.
Subject access requests
Please note that under the General Data Protection Regulation, individuals are entitled, subject to certain exceptions, to request access to information held about them.
If you receive a subject access request, you should refer that request immediately to the DCO. We may ask you to help us comply with those requests.
Please contact the Data Compliance Officer 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.
Processing data in accordance with the individual’s rights
- You should abide by any request from an individual not to use their personal data for direct marketing purposes and notify the DCO about any such request.
- Do not send direct marketing material to someone electronically (e.g. via email) unless you have an existing business relationship with them in relation to the services being marketed and have opted-in to receive electronic direct marketing.
- Please contact the DCO for advice on direct marketing before starting any new direct marketing activity.
- All staff will need to read this policy. New joiners will receive training as part of the induction process. Further training will be required at least every two years or whenever there is a substantial change in the law or our policy and procedure.
- The law relating to data protection
- Our data protection and related policies and procedures
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 protectionBeing transparent and providing accessible information to individuals about how we will use their personal data is important for our organisation. The following are details on how we collect data and what we will do with it:
|What information is being collected?||Customer, Supplier and employee contact details. Payment information|
|Who is collecting it?||Accounts, Sales & Purchasing departments|
|How is it collected?||Completion of Customer Application Form, Supplier Agreement Form and Employee New Starter Form.|
|Why is it being collected?||To ensure correct and accurate information is held on file.|
|How will it be used?||This will be used to process sales orders for our customers, purchase orders to our suppliers and payroll for employees.|
|Who will it be shared with?||Not outside organisations, other than Government requests|
|Identity and contact details of any data controllers||Passport identification is held on file of Data Controller/Processors|
|Retention period||7 years for accounting and HMRC requirement. Personal data with no activity, 1 year|
- Conditions for processing
Justification for personal dataWe will process personal data in compliance with all six data protection principles.
We will document the additional justification for the processing of special categories of personal data, and will ensure any biometric and genetic data is considered a special category of personal data.
ConsentConsent given must be just as easy to revoke. Consent may be revoked at any time and actioned immediately. Be aware that all marketing data must give the option to unsubscribe.
Criminal record checksAny criminal record checks are justified by law. Criminal record checks cannot be undertaken based solely on the consent of the subject.
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. A data subject may also request that their data is transferred directly to another system. This must be done for free.
Right to be forgottenA 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.
Data audit and registerRegular 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.
All members of staff 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 Supervisory Authority (SA) of any compliance failures that are material either in their own right or as part of a pattern of failures
Consequences of failing to comply
We take compliance with this policy very seriously. Failure to comply puts both you and the organisation at risk.
The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in dismissal.
If you have any questions or concerns about anything in this policy, do not hesitate to contact the DCO.