The purpose of this statement is to provide information regarding how and we, process and store data, as well as providing the appropriate contact information should you wish to request the information we hold about you, withdraw from processing or request deletion of any data we hold about you.
Under the EU General Data Protection Regulation (GDPR) there are six lawful bases for processing personal data. These are detailed as follows:
Consent – the individual has given clear consent for you to process their personal data for a specific purpose
Contract – the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract
Legal Obligation – the processing is necessary for you to comply with the law (not including contractual obligations)
Vital Interests – the processing is necessary to protect someone’s life
Public Task – the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law
Legitimate Interests – the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
Further information regarding the lawful basis for processing personal data can be found at ico.org.uk
As an organisation that processes business related data, we have assessed all six grounds for lawful processing of personal data and has selected ‘Legitimate Interests’ as the most suitable lawful ground for the processing of data.
We collect, process and store data relating to businesses and decision makers. We believe that the individuals that we process the data of, are likely to have an interest in our products and/or services. Deemed as ‘Legitimate Interest’ this is based upon specific criteria including the business industry sector, size of organisation as well as the individual’s job function within the organisation.
The data collected will be used to communicate marketing and sales messages relating to our products and services. We specifically only send messages to those we believe are likely to be interested in our services based upon the organisation they are employed by and based upon their job function within that organisation.
When you send us an enquiry or booking form via our website you will be asked to provide your contact details. We will use the data you provide to process your request and may use it to inform you by email, telephone or mail about other services that we feel may be of interest to you. It is deemed that if you have visited one of our websites and provided us with your contact information that you are legitimately interested in our products and services. You have the right to object from any method of correspondence at any time, using the unsubscribe button on an email, by informing the telephone operator or by contacting us via any of the methods below.
How we Procure Data
We procure data in a variety of ways, collected in line with the lawful basis of ‘Legitimate Interests’. If you have received correspondence from us, we will have procured your data in one of the following ways:
You have requested information on a previous occasion
Someone has sent us your e-mail address requesting information about our articles and/or services be sent to you.
You or someone else has expressly shared your contact details with us for the purpose of receiving information now and/or in the future
We have previously met at an event and your business card or contact details were handed to us willingly
You or a business colleague has visited our website and we believe that there is a genuine legitimate interest in our services
You have previously connected with a member of our team at the venue and discussed our services
Email marketing tracking
Tracking email opens
When we send marketing emails promoting any of our services we track if you have opened a marketing email. We use these in our HTML-based emails to let us know which emails have been opened by recipients. They allow us to gauge the effectiveness of certain communications, and the effectiveness of our marketing campaigns.
Tracking email clicks
When we send marketing emails we personalise each link in each email with unique code to enable us to track whether the recipient has clicked on the link in the email. This allows us to gauge the effectiveness of certain communications, and the effectiveness of our marketing campaigns. We also combine the information gathered in emails to our customers’ personal data. If you would like to opt-out of these emails you can do so by clicking on the unsubscribe link in the footer of each email we send you.
Telephone calls
All telephone calls are recorded, for training and security. We store these calls and the telephone numbers and may use them at time to time for marketing purposes. Again we will only use information from people who have contacted us, we do not use mailing lists.
CCTV
The premises are covered by Closed Circuit Televsion, and images are recorded to protect ours and our customers property. We will share this information with the Police or the Courts if required to do so, in the event of criminal activity.
Legitimate Interest Assessment (LIA)
We have carried out a Legitimate Interest Assessment (LIA) as advised by the ICO. Based upon that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our correspondence regarding our Companies and that in no way would a data subject be caused harm by our correspondence. Based upon our segmentation by organisation and by specific job function, coupled with our processing of personal data within the context of a business environment, we believe that any individual that receives correspondence from us in a direct marketing or sales capacity, could be legitimately interested in our services. It is also deemed that direct marketing and sales is necessary in the context of promoting our Companies to professionals in business in order to increase awareness of our ICT Products and services.
Per the ICO guidance, we can confirm:
We have checked that legitimate interests is the most appropriate basis
We understand our responsibility to protect the individual’s interests
We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision
We have identified the relevant legitimate interests
We are not using people’s data in ways they would find intrusive or which could cause them harm
We do not process the data of children
We have considered safeguards to reduce the impact where possible
We will always ensure there is an opt-out / ability to object
Our LIA did not identify a significant privacy impact, and therefore we do not require a DPIA
We keep our LIA under review every six months, and will repeat it if circumstances change
We include information about our legitimate interests in this privacy notice
Data Storage and Retention
We will use your data to update you with details of our product and service offerings, However, we will delete your data should you no longer show interest in these details at a time 5 years after the last verifiable contact we have with you.
We will use your data to update you with details of our product and service offerings, However, we will delete your data should you no longer show interest in these details at a time 5 years after the last verifiable contact we have with you.
Security of personal data
Appropriate measures
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse, or alteration of your personal data.
Secure storage
We will store all your personal data on secure servers, personal computers, and mobile devices, and in secure manual record-keeping systems.
Financial transactions
Data relating to financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
Acknowledgement of you transmitting unencrypted data
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of that data sent over the internet
Providing your personal data to others
We will not share your data with anyone outside of our companies.
Your personal data may be stored in our data centre, on our telephony system and servers where it may be accessed by third party administrators so far as is reasonably necessary for the safe and efficient storage of your data. We may use third parties such as email service providers and campaign analytics services who may process your personal data at our request in order to maximise the efficiency of our communications with you.
Our payment providers
Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds.
Our productivity and communication application providers
For compliance with a legal obligation
In addition to the specific disclosures of personal data set out in this Privacy Policy, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Right to Object
In all correspondence with you we will give you the right to object from receiving further correspondence from us. On any emails you receive from us there will be the option to ‘unsubscribe’ from receiving any further email correspondence. If you receive a telephone call from us, you have the right to request not to receive any further calls.
Should you wish to object to receiving communication from us, you can do so in a variety of ways:
Please click the ‘unsubscribe’ link at the bottom of every email
If you have received a call, please tell the representative that you do not wish to receive any further communication
You can also make your request by emailing:
Or by writing to:
The Manager, West Midlands Golf Club, Marsh House Farm Lane, Barston, Solihull, B92 0LB
All requests will be processed within 30 days. We wont remove your data but will not send our promotional emails to you. Please note this applies only to the processing of your personally identifiable data, not that of the business data which does not fall under the remit of GDPR.
Right to Request Erasure
It is important to understand the difference between a right to object and a request for deletion. If you make a request for deletion, we will remove any data we hold about you from our system. This will also mean that we will remove you from our suppression files. If you are removed from our suppression files, there is a risk that your data may be processed again in the future if your details are re-added to our system by a member of our sales team who genuinely believes that you would benefit from our services. If you do not wish for us to contact you again about our services, we would recommend you request to object rather than make a request for deletion, as this will ensure that your details are always suppressed from processing.
The option however is yours, and in either case we will process your request within 30 days.
Right to Access
You may request that we send you all of the data we hold that relates to you. Please make your request in writing;
Under the GDPR you have a number of data privacy Rights including those listed above. For more information on these rights please see the website of the Information Commissioner’s Office at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
This policy was last reviewed and updated on the 25th May 2018. Policies are periodically reviewed to ensure compliance with the current compliance environment.
For further information on the GDPR as well as other Data Protection and Data Privacy issues and regulations please visit www.ico.org.uk
On behalf of John Harrhy & Sons Ltd
Trading as;
West Midlands Golf Club
Widney Manor Golf Club
The Lake at Barston Restaurant / Conference Centre
Barston Lakes
