Privacy Notice (Fair Processing Notice)

The privacy and security of your information is important to us. This notice explains who we are, the types of information we hold, how we use it, who we share it with and how long we keep it. It also informs you of certain rights you have regarding your personal information under current data protection law. We will review and update this notice on a regular basis. The terms used in this Fair Processing Notice are based on the Information Commissioner’s Office. You can find out more about the ICO here: https://ico.org.uk.

Who are we?

QSMP is a sales and marketing company working on behalf of brand owners, typically those looking to gain activation on the UK On-Licensed Trade.

QSMP is the Data Controller of the information you provide us and is registered with the Information Commissioner’s Office for the services we provide (Registration Number ZA354353)

You can contact us for general data protection queries by email to data.request@qsmp.co.uk or in writing to The Data Protection Officer, QSMP, Unit 3 West Court, Saxon Business Park, Hanbury Rd, Bromsgrove, B60 4AD. Please advise us of as much detail as possible to comply with your request.

Purpose, Data Types and Data Subjects

QSMP as Data Processor will process personal data on behalf of the Data Controller (typically our Customer/Brand Owner or Wholesaler/Route to Market) for the purposes of carrying out the services as specified in our contract or agreement.

We will typically process the following types of personal data provided by you: Name, Mobile Telephone Number, Fixed line Telephone Number and Email address.

We may also process data including your business Account Number with the supplying Brewer, Wholesaler or Route to Market.

The typical category of data subjects processed by QSMP are Customers of specified Pub Companies, Brewers or Wholesalers, or Small Business Owners. Additional categories may be included on occasions as required and specified by the Data Controller as necessary to fulfil the obligations of our contract.

All telephone calls are recorded either for contractual purposes or for training and coaching. These call recordings are encrypted and password protected and only accessible by the Data Manager.

 
The personal data we collect will be used for the following purposes:

To communicate with you by telephone, post or email about orders for the brands or services we represent which you have placed directly with us or with the relevant Wholesaler, Brewer or Route to Market.     

To discuss products or services that are closely related to those that you have purchased in the past provided by the Brand Owner or Wholesaler, Brewer or Route to Market we represent.

Our legal basis for processing for the personal data:

·        Verbal consent given by yourself, which can be withdrawn at any time

·        Data we are obliged to collect relating to a contract

·        It is in the legitimate interest of our Brand Owner Customer to communicate products and services that are similar to those previously supplied by the Brand Owner, Wholesaler or Route to Market partners that we are contracted to work with.

Article 6(1f) of the GDPR states that processing is lawful if, and to the extent that:

“Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child”

The special categories of personal data concerned are:

·        none

Securing your personal information

QSMP has a professional range of physical and digital security tools and processes in place to safeguard our building, server and network.

We follow strict security procedures in the storage and disclosure of your personal information in line with industry practices, including storage in electronic and paper formats.

Any new information you provide us may be used to update an existing record we hold for you.

No data is stored or sent to any location outside of the EU, and no use is made of data sub processors

When do we share your information?

QSMP will not pass on your personal data to third parties without first obtaining specific consent to do so.

A common situation where it will be necessary to pass on basic personal details are where you have agreed to place an order with us for goods or services and we are required to pass on details of that order to the wholesaler, brewer or Route to Market that is scheduled to fulfil that order. We are also required to pass on basic personal data where we have agreed with you to supply to your business premises some relevant marketing support materials (e.g. Point of Sale items).

If we provide information to a third party we will require it and any of its agents and/or suppliers to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Fair Processing Notice.

How long do we keep your information for?

We will not keep your personal information longer than is necessary for the purpose for which it was provided unless we are required by law or have other legitimate reasons to keep it for longer.

We will review data held under the basis of consent and Legitimate Interests every 2 years to check there is a valid basis on which to hold the data.

Your rights

There are a number of rights that you have under data protection law. Commonly exercised rights are:

• Information – You have the right to be informed about how we process your data. Such information forms the basis of this Privacy Notice
• Access – You may reasonably request a copy of the information we hold about you. Such data access requests should be made to data.request@qsmp.co.uk or in writing to The Data Manager, QSMP, 3 West Court, Saxon Business Park, Hanbury Rd, Bromsgrove B60 4AD. We will respond to such requests within 28 days of receipt.
• Rectification – You have the right to correct data held by QSMP that is incomplete of inaccurate
• Erasure - Where we have no legitimate reason to continue to hold your information, you have the right to have your data deleted (sometimes known as the right to be forgotten). To enact this please email data.request@qsmp.co.uk  or write to The Data Manager, QSMP, 3 West Court, Saxon Business Park, Hanbury Rd, Bromsgrove          B60 4AD
• Portability – You have the right to request QSMP transfer any data we hold on you to another company.

·        Right to object – you have the right to object to certain types of processing such as direct marketing.

·        Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

·        Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain – as outlined below.

Complaints

If you are unhappy about the way we have handled your data or upheld your rights, you can complain to the Information Commissioner’s Office (ICO) at any time.

Further details of your rights can be obtained by visiting the ICO website at https://ico.org.uk.