Howard’s Way Data Privacy Policy

This policy refers to Howard’s Way and how personal data is processed in compliance with the Data Protection Act (DPA) 1998 and the new General Data Protection Regulation (GDPR) which comes into effect from 25th May 2018.  This policy applies to data subjects of Howard’s Way and users of www.howardswayrothesay.co.uk.  The use of cookies and analytic software is also explained. 

Headings within this policy are inserted for the convenience of the reader only and are not to be considered when interpreting this policy.

Terminology

Personal data is any information that could identify a person (data subject).  Personal sensitive data relates to information concerning a data subject’s racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, or details of criminal offences.

A data subject is any identified or identifiable person whose personal data is processed by the data controller.

A data controller determines the purposes for data processing and the way personal data is processed.

Processing is any action or actions performed on personal data such as collection, organisation, storage, erasure or destruction.

Data Collection

Howard’s Way collects personal data because it is required for the provision of products and services.

Howard’s Way collects contact details such as names, addresses, telephone numbers and email addresses.  Any additional data received by email, letter, telephone, through www.howardswayrothesay.co.uk or by any other means of correspondence is also collected.  Data subjects are required to agree to this policy before submitting their personal data through the contact form on www.howardswayrothesay.co.uk.

Howard’s Way can store personal data obtained from social media interactions outside of social media platforms if correspondence regarding products and services is received.

Howard’s Way may receive personal data from trusted third parties such as room booking websites.  Personal data collected this way is used for the provision of products and services in accordance with requested requirements.

Some public areas are covered by CCTV for security reasons.  These images are stored on a separate, offline server and are kept for no longer than legally allowed.

Personal data is not collected or retained when Howard’s Way WIFI is used.

Data Protection

Howard’s Way has security measures in place to protect personal data from theft, loss and breach of privacy.  Security measures include password protection, restricting access to personal data to authority figures within Howard’s Way, and a Firewall (security software) in place to protect internal information from the internet.

Howard’s Way does not sell, rent or trade email lists with third parties for marketing purposes.

Data Retention

Howard’s Way retains personal data for no longer than it is necessary for tax purposes, the reason(s) it was originally collected and where otherwise required by law.  Personal data can be reviewed at any time to determine whether it is still needed which can result in the destruction of personal data.

Howard’s Way destroys all personal data at the end of a customer’s stay.  Please be aware that companies can keep personal data for longer if kept for public interest archiving or statistical purposes.

General

Howard’s Way acts as a data controller by processing personal data.  Processing is always with legitimate interest and compatible with the reason(s) the data was originally collected.

Howard’s Way uses personal data to provide data subjects with products and services.  Howard’s Way may contact data subjects regarding products and services and in response to enquiries.

Howard’s Way may be required to process personal data for investigating, detecting and reporting crime; to demonstrate compliance and to actively comply with industry standards and any laws and acts that may apply.

www.howardswayrothesay.co.uk may contain links to external websites.  Howard’s Way is not responsible for the practices of other websites and encourages visitors to read the privacy policies of every website that collects personal data.

Cookies

Data may be obtained from cookies through www.howardswayrothesay.co.uk.  Cookies are small text files that are placed on a device by websites when they are visited.  Cookies enable delivery of more personalised content and are widely used to make websites work or work more efficiently.

Most web browsers allow some control of most cookies through the browser settings.  Please note that in a few cases some website features may not function if cookies are removed from the browser.

Google Analytics

When www.howardswayrothesay.co.ukis visited, a third-party service called Google Analytics is used to collect standard internet log information and details of visitor behaviour patterns.  This is to discover factors such as the number of visitors to various parts of the website.

This information is processed in a way that does not identify anyone; Howard’s Way does not make, and does not allow Google to make, any attempt to find out the identities of those visiting www.howardswayrothesay.co.uk.

Rights

Data subjects have the following rights regarding their personal data:

The right to be informed

Data subjects have the right to clear, transparent and understandable information regarding their rights and how Howard’s Way uses their personal data.  This is the purpose of providing data subjects and visitors to www.howardswayrothesay.co.uk with a data privacy policy.

The right of access

Data subjects have the right to access their personal data that is being processed by Howard’s Way.

The right to rectification

Data subjects are entitled to correct their personal data if it is inaccurate.

The right to be forgotten / erasure

Data subjects are entitled to request the deletion of their personal data where there is no exigent reason for Howard’s Way to continue processing it.  Please be aware that there are exceptions to erasure.

The right to restrict processing

Data subjects have the right to put an end to the processing of their personal data in certain circumstances.  Howard’s Way can continue to store personal data when processing is restricted but may not further process it.

The right of data portability

Data subjects have the right to acquire and reuse their personal data, as well as the right to have their personal data directly transferred to third parties in certain circumstances.

The right to object

Data subjects have the right to object to Howard’s Way processing their personal data.

The right to withdraw consent

Data subjects who have given consent to Howard’s Way to process their personal data have the right to withdraw their consent at any time.  Any processing of the data subject’s personal data up to that point is not unlawful.

The right to complain

Data subjects have the right to make a complaint to the Information Commissioner’s Office (the data protection authorities) if they believe their personal data has not been processed in compliance with data protection law.

Please contact Howard’s Way to arrange a suitable time to discuss personal data and the practise of rights.  Contact details can be found at www.howardswayrothesay.co.uk/contact-us.

Howard’s Way may occasionally update this policy therefore data subjects and visitors to www.howardswayrothesay.co.uk may want to review it each time personal data is provided.