PRIVACY STATEMENT

When customers make a booking at the Creel B&B, they share with us only their names, addresses (postal and electronic), and their telephone numbers.

These are noted by us, stored safely on a password protected computer, and used SOLELY for communicating with them.
​
This information is NEVER shared nor disclosed to anyone else for any purpose whatsoever.

(The Creel B&B is aware that in certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. We would need to be presented with a proper warrant, and further verify the validity thereof, before even considering releasing the minimal information listed above that we keep. Fortunately, this has never happened and we rather suspect it never will!)
​
Below you will find our data protection policy which we have put in place in compliance with the General Data Protection Regulation which will apply from 25 May 2018 but which we already implement.

Data protection policy under
​the General Data Protection Regulation - 25 May 2018 

Context and overview
Key details
  • Policy prepared by:                David Sinclair-Loutit
  • Policy became operational on:        25 April 2018     
  • Next review date:                25 April 2019    
Introduction
The Creel B&B is provided with certain information about individuals when bookings are made or in contacts with suppliers.
These can include customers, suppliers, business contacts, and other people the B&B has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored to meet data protection standards — and to comply with the law.
Why this policy exists
This data protection policy ensures the Creel B&B:
  • Complies with data protection law and follow good practice 
  • Protects the rights of customers and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach

Data protection law
The Data Protection Act 1998 describes how organisations — including the Creel B&B— must collect, handle and store personal information. 
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The Data Protection Act is underpinned by eight important principles. These say that personal data must:
  1. Be processed fairly and lawfully
  2. Be obtained only for specific, lawful purposes
  3. Be adequate, relevant and not excessive
  4. Be accurate and kept up to date
  5. Not be held for any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection


People, risks and responsibilities
Policy scope
This policy applies to all data that the Creel B&B holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • …plus any other information relating to individuals

Data protection risks
This policy helps to protect the Creel B&B from data security risks, including:
  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
    Note: the Creel B&B only records the names and contact details supplied to it by its customers and suppliers and ‘uses’ these solely for the purpose of communicating with them. The Creel B&B never shares these details with anyone for any reason.
  • Reputational damage. For instance, The Creel B&B could suffer if hackers successfully gained access to sensitive data.

Responsibilities
Everyone who works in or with The Creel B&B has some responsibility for ensuring data is collected, stored and handled appropriately.
Personal data is handled and processed in line with this policy and data protection principles. 


General guidelines
  • The only people able to access data covered by this policy are those who need it for their work.
  • Data is not shared informally.
  • All data  is kept secure, by taking sensible precautions and following the guidelines below.
  • In particular, strong passwords are used and are never be shared.
  • Personal data is never disclosed to unauthorised people, either within the company or externally.
  • Data is regularly reviewed and updated if it is found to be out of date. If no longer required, it is deleted and disposed of.

Data storage
These rules describe how and where data is safely stored. 
When data is stored on paper, it is kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
  • When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • Paper and printouts are not left where unauthorised people could see them, like on a printer.
  • Data printouts are shredded and disposed of securely when no longer required.
When data is stored electronically, it is protected from unauthorised access, accidental deletion and malicious hacking attempts:
  • Data is protected by strong passwords that are changed regularly and never shared.
  • If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
  • Data is only be stored on designated drives and servers, and is only uploaded to an approved cloud computing service.
  • The computer containing personal data is sited in a secure location, away from general office space.
  • Data is backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • The computer containing data is protected by approved security software and a firewall.


Data use
Personal data is of no value to The Creel B&B unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
  • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • Data must be encrypted before being transferred electronically. 
  • Personal data should never be transferred outside of the European Economic Area.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.


Data accuracy
The law requiresThe Creel B&B to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort The Creel B&B should put into ensuring its accuracy.
  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
  • The Creel B&B will make it easy for data subjects to update the information The Creel B&B holds about them. For instance, via the company website.
  • Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.




Subject access requests
All individuals who are the subject of personal data held by The Creel B&B are entitled to:
  • Ask what information the company holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date. 
  • Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request. 
Subject access requests from individuals should be made by email, addressed to the data controller at infor@thecreel.co.uk. The data controller can supply a standard request form, although individuals do not have to use this.
Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.




Disclosing data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, The Creel B&B will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance The Creel B&B's legal advisers where necessary.


Providing information
The Creel B&B aims to ensure that individuals are aware that their data is being processed, and that they understand:
  • How the data is being used
  • How to exercise their rights 
    ​
To these ends, the company has a privacy statement at the top of this page setting out how data relating to individuals is used by The Creel B&B.