1.IMPORTANT INFORMATION AND WHO WE ARE
|Full Name of Legal Entity:||Redhill Aerodrome Limited|
|Data Privacy Manager:||Tom Slack|
|Postal Address:||Redhill Aerodrome Business Centre, Kings Mill Lane, Redhill, Surrey RH1 5JZ|
|Telephone Number:||07768 827486|
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.
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
This 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. W
2.DATA WE COLLECT ABOUT YOU
Personal Data 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).
Redhill Aerodrome Limited may collect, use, store and transfer the following different kinds of personal data about you:
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 an existing contract or enter into a new contract with you. In such a case, we may have to cancel a product or service you have with us but will notify you at the time if this is the case.
METHODS OF COLLECTING YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
In addition, your image may be recorded by our CCTV cameras at the Aerodrome and, to the extent that you are identifiable from those images or in combination with any other person, this may also amount to Personal Data.
3.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:
See the Glossary, and the definition of Lawful Basis to find out more about the types of lawful basis that we will rely on to process your personal data.
We do not rely on consent as a legal basis for processing your personal data. If at any time this changes, and we ask for your consent to process personal data, you will have the right to withdraw consent at any time by contacting us although by doing so we may not be able to continue to provide certain services to you. We will advise you at the time if that is the case.
PURPOSES FOR WHICH WE 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.
Please 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 supplier
(b) Contact details
Performance of a contract with you
To process and deliver services to and/or from you:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(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:
(b) Asking you to leave a review or take a survey
(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 administer and protect our business and this 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 maintain any records or details that we are required to keep to comply with regulatory requirements.
Necessary to comply with a legal obligation.
At present, we do not carry out, or intend to carry out, any marketing or advertising activities that would involve processing your personal data.
Similarly, we do not share your personal data with any third party for the purpose of marketing.
4.DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table in section 3 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5.TRANSFERRING YOUR PERSONAL DATA ABROAD
We do not transfer your personal data outside the European Economic Area (EEA).
SAFETY AND 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.
DURATION OF DATA RETENTION
We will only retain your personal data for as long as we need it to meet the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirement. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 by contacting us.
In some circumstances you can ask us to delete your data: see “Your Legal Rights” in section 6 below.
We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in these cases we may use this information indefinitely without further notice to you.
6.YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws as follows:
Further details of these legal rights are set out in the Glossary under “Your Legal Rights”.
Please contact us if you wish to exercise any of the rights set out above.
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.
We try to respond to all legitimate requests within one month. Occasionally, it could take longer if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.
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).
LIST OF WEBSITES COVERED BY THIS POLICY
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 are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Other companies in the Group acting as joint controllers or processors and who are based in England and provide administration services.
External Third Parties
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:
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.