Privacy notice

BELLWAY GROUP

Privacy Notice

“REST OF THE WORLD”

for individuals not covered by a SPECIFIC privacy notice

This notice applies to you if we process your personal information and you are not an employee or worker of ours, a prospective candidate employee or worker, a prospective customer or customer of ours or an individual to whom we have provided a specific privacy notice. You may be, for example, be an individual that works at a supplier or another organisation that we deal with, an attendee at one of our events, a user of our website or someone who is affected by our activities.

References to weour or us in this privacy notice are to the Bellway Group (being Bellway p.l.c. and each of its direct and indirect subsidiaries, trading under the “Bellway" or the “Ashberry” brands. Details of our main trading entities are as follows:

Both companies have their registered office at Seaton Burn House, Dudley Lane, Seaton Burn, Newcastle upon Tyne, NE13 6BE.

We have appointed a Data Protection Officer to oversee our compliance with data protection laws and they have overall responsibility for data protection compliance in our organisation. Contact details are set out in the “Contacting us“ section at the end of this privacy notice.

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your relationship with us. This notice explains how we comply with the law on data protection and what your rights are and for the purposes of data protection the company in our Group which is processing your personal information will be the controller of any of your personal information.

1.         PERSONAL INFORMATION WE COLLECT

We may collect the following types of personal information about you:

2.            SPECIAL CATEGORIES OF PERSONAL INFORMATION

We do not generally collect, store and use the following “special categories” of more sensitive personal information regarding you:

If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information.

Also we will not generally collect, store and use any criminal records information in relation to you. If we do collect any criminal records information, we do not currently rely on consent as a basis for processing criminal records information.

3.         SOURCES WE COLLECT YOUR PERSONAL INFORMATION FROM

We will collect personal information from a number of sources. These may include the following:

4.            WHAT WE USE YOUR PERSONAL INFORMATION FOR

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this. Which will apply will depend upon the nature of your relationship and interactions with us.

 Purpose

Personal information used

Lawful basis

Identity and money laundering checks and passing details of our money laundering checks to third parties and to carry out credit checks

All the personal information we collect

We may have a legal obligation to undertake identification and money laundering checks and to provide those details to third parties

We and a third party also have a legitimate interest in knowing your identity and carrying out money laundering checks and ensuring that we are likely to be paid

Enter into and perform contracts, where we may be supplying products/services to you and/or you may be supplying products/services to us or we may be involved in similar arrangements with third parties

All the personal information we collect

To enter into and perform contracts with either yourself or the organisation that you represent

We have a legitimate to properly perform contracts with third parties

Deal with your queries, complaints, claims or legal disputes or raise queries, claims, legal disputes or complaints with you

All the personal information we collect

This may be necessary to perform a contract with you or the organisation that you represent

We have a legitimate interest to improve the services and/or products we provide

To defend, bring or establish legal claims

Maintain and improve our services and/or products

All the personal information we collect

We have a legitimate interest to improve the services and/or products we provide

Data analytics, use of cookies and statistical analysis to help us improve our online services

How you use our website

We have a legitimate interest to improve the online services we provide and user experience

Determine services and/or products that may be of interest to you

All personal information we collect

We have a legitimate interest to improve the services and/or products we provide and to determine which products and/or services you may be interested in

To provide you with requested information

Contact details and services and products or other information that you have requested we provide to you or your organisation

To comply with any request made by you

Direct marketing, targeted advertising and social media advertising, marketing or promotions

Contact details, personal identifiers and services and products that we have determined may be of interest to you or your organisation and/or which you or your organisation has purchased in the past or which you have indicated you or your organisation may be interested in

We may ask for your consent to process your data for this purpose, you may revoke your consent at any point. Alternatively we may market or carry out advertising or promotions in relation to our products or services as a legitimate interest in developing our business.  You have the right to opt out from any direct marketing at any time

Holding events

Your contact details, details of attendance, your comments in response forms and dietary requirements and CCTV images

We have a legitimate interest in holding events and tracking attendance and providing appropriate food and drinks at events

We may also have a legal obligation to comply with health and safety requirements

To comply with our legal and regulatory obligations

All the personal information we collect

To comply with any legal and regulatory obligation or requirement

Fraud, crime prevention and debt collection

All the personal information we collect

We have a legitimate interest to detect and prevent crime and to collect debts.

To manage our relationship with you and to operate our business

All the personal information we collect

We have a legitimate interest to operate our business in an efficient way and to expand our business

To enter into and perform contracts with either yourself or the organisation that you represent

Storage of records relating to you and also records relating to our business

All the personal information we collect

To be able to manage and fulfil any contract with you, we may have a legal obligation to do so and we also have a legitimate interest to keep proper records

For some of your personal information you may have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or the organisation you represent or comply with legal obligations and we may have to terminate our relationship. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our arrangements with you or the organisation you represent.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us section below. We will generally only ask for your consent for direct marketing.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide marketing information to you.

We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and services.

5.         WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We may share personal information with the following parties:

We also use Google Analytics which sets cookies to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

We may provide third parties with aggregate statistical information and analytics about users of our products and services but we will make sure no one can be identified from this information before we disclose it.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally entitled to do so. We do not sell your data.

6.         TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union except as set out in this section.

Our directors and other individuals working for us may in limited circumstances access personal information outside of the UK and European Union if they are on holiday abroad outside of the UK or European Union. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.

In limited circumstances the people to whom we may disclose personal information as mentioned in section 6 above may be located outside of the UK and European Union. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us section below.

7.         HOW LONG DO WE KEEP PERSONAL INFORMATION FOR

We will keep your personal information for as long as is necessary for the purpose for which it has been obtained and then for as long as there is any risk of a potential claim, which will be dependent upon the limitation period for the particular type of claim. We have set out below the main retention periods which will apply:

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let your usual contact at Bellway know if anything changes, for example if you move position or work for a different organisation or change your phone number or email address.

8.         SECURITY

We have numerous security measures in place to protect the loss, misuse and alteration of information under our control, such as passwords and firewalls. We cannot, however, guarantee that these measures are, or will remain, adequate. We do, however, take data security very seriously and will use all reasonable endeavours to protect the integrity and security of the personal information we collect about you.

9.         YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

You have the following rights in relation to your personal information:

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example we do not use automated decision making in relation to your personal data. However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

10.       CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

 

11.       CONTACTING US

In the event of any query or complaint in connection with the information we hold about you, please email data.protection@bellway.co.uk or write to the Data Protection Officer at Seaton Burn House, Dudley Lane, Seaton Burn, Newcastle upon Tyne, NE13 6BE.