Privacy Policy

What is this notice for?

This notice explains what we do with your personal data and the steps we take to keep it secure. It explains when and how we collect personal data, who we share it with, how we process it and what your rights are in respect of the personal data processing we carry out.

Who is Greene King Pub Partners?

Greene King has a 200-year tradition of brewing great beers and helping people to run great pubs. Our Pub Partners division has pubs available across England, Scotland and Wales and a range of innovative agreements.

When we say 'we', 'us' or 'our' in this notice, we are referring to Greene King Brewing and Retailing Limited. We are the data controller in respect of this website and the services described in this notice. Our ICO (Information Commissioner's Office) registration number is ZA054235.

When do we use your personal data?

We believe that a good licensee experience means:

·  Giving you relevant information about our company, pubs, products and offers

  Helping you choose the right agreement and the right pub to operate

  Providing you with excellent business support and training and a range of other services designed to help you make the most of your business

 

To do these things well, we need to process some of your personal data. We do this whenever

  you use our websites

  you make an initial enquiry about our pubs and we send you direct marketing

  you contact us through Live Chat on our website www.greenekingpubs.co.uk

  you opt out of direct marketing

  you go through the application process to become one of our partners

  you undertake training either before or once you become one of our partners

  we help you run your business with direct support

  we market relevant services to you

  you join one of our special interest groups, such as our Sports Club

  we manage our relationship with you

  we conduct surveys with you to obtain your feedback about us

  we deal with the licensing arrangements for your pub

  you make a payment, use our online ordering system or request a refund

  you submit queries or complaints

  when there is an insurance claim

  when we ask for other people's data

 

It's worth remembering that personal data, which is covered by this notice, refers to information about you as an individual. Information about any companies that you own or operate through is not personal data.

Where we do hold personal data on you, we don't keep it for any longer than we need it. See our retention periods for more details.

Sometimes we need to share your personal data with other Greene King companies or with other organisations that help us provide our products and services to you. We will not sell your personal data and we do not allow these organisations to use your personal data for anything that's not described in this notice. We might also need to share your personal data to uphold your rights, our rights or the rights of other people and we may need to share your personal data to meet some of our legal obligations. See the data sharing section for more details.

You can find out more about how we meet our data protection law obligations here. This section also explains what rights you have in respect of the personal data processing we do, and how you can exercise them.

How can you contact us?

If you want to discuss how we use your personal data

• Write to us at Greene King Pub Partners, Westgate Brewery, Bury St Edmunds, Suffolk, IP33 1QT
• Send an email to ppadministration@greeneking.co.uk
• Call us on 01284 763222

If you want to contact our Data Protection Officer

• Write to the Data Protection Officer, Greene King, Westgate Brewery, Bury St Edmunds, Suffolk, IP33 1QT
• Send an email to dataprotection@greeneking.co.uk

How do we use your personal data?

When you use our websites

Most of our websites use cookies. Cookies are small text files which websites store on the device you use to access our websites. Some cookies contain personal data. In general, we use cookies to run our websites, monitor their use and understand how our customers use them. See our cookie policy for more details.

 

When you make an initial enquiry about our pubs and we send you direct marketing

When you make an initial enquiry about our pubs by signing up for pub alerts, research information or planning information, we will ask for your name, phone number, email address, the region you are interested in, and how far you are progressed with your business plans so that we can send you some direct marketing.

We use the information you provide to personalise our direct marketing, such as by addressing you by name, and targeting our marketing based on where you live. We will not send you excessive amounts of marketing and every marketing message we send includes an easy way for you to opt out.

When you contact us using Live Chat on our website

If you talk to us on our live chat service, you will be sharing your name and e-mail address for the purposes of identifying yourself to us and so that we can send you a transcript of your chat with us. In addition to this information, our live chat system will place a cookie in your browser which will persist until you quit your browser, please see our cookie policy for more information. This is required to ensure that your live chat can continue across all pages on our website. We also use records of live chats for staff training to improve our service to you.

If you opt out of direct marketing

You can opt out of receiving direct marketing at any time by following the unsubscribe instructions in any of our marketing messages, or by contacting ppadministration@greeneking.co.uk

When you go through the application process to become one of our licensees

When you decide that you are ready to apply for one of our pubs, we ask for more information from you. We ask for your title, full name, maiden name (if applicable), address, date of birth, phone number and email address. We also ask for how you are likely to want to operate the pub (sole trader, partnership or limited company) and for further information to help us get to know you better. This includes your recent trade or business experience, a CV, whether you have had any specific training on running a pub, the amount and source of funding available to you and whether you have ever been declared bankrupt or have any county court judgments against you.

To progress your application further you will need to provide proof of your ID such as a copy of your passport, proof of funding and a business plan. You will be asked to sign a credit check consent form to enable us to verify your creditworthiness as part of our recruitment process. We will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at https://www.equifax.co.uk/crain

Greene King will continue to run periodic credit checks for the duration of the account to ensure ongoing creditworthiness is maintained.

We will use all of this information, as well as information from third parties to help us decide whether to grant a Greene King lease or tenancy to you. Please see the section on who we share data with for more information.

When you undertake any training either before or once you become a Greene King licensee

A key part of being a Greene King licensee is that we offer training to prospective and current licensees in a range of areas, to help you make the most of your business, some of which is mandatory. We will keep a record of any training you undertake at our request.

When we help you run your business with direct financial support

We can provide you with specific help to run your business. This can include direct financial support via our assisted purchase agreements or help with investment in your pub or help if your business is struggling. To qualify for these you will need to provide information on your financial position (latest accounts and VAT returns, stock take results, bank statements, debts) and on what you are looking to do to and how it will improve your business.

When we market relevant services to you

We run promotions from time to time and can help our licensees save money on things you need to run your business. This includes beer and other drinks, food, utilities, card processing services and a range of other goods and services. To do this we may share some licensee details (name, address, phone number, email address and agreement details) with our suppliers. Please see the section on who we share data with for more information.

When you join one of our special interest groups such as our Sports Club

We run a number of special interest groups designed to cater for pubs with specific offers, such as our Sports Club and to join you will need to provide us with details of your pub offer.

When we manage our relationship with you

We use the personal data that you provided to us as part of your application process, any further information that you provide or that we acquire during the course of your tenancy or any changes that you advise us from time to time to manage our relationship with you as your landlord, to communicate with you and to ensure that we and you comply with our respective obligations under the lease or tenancy agreement and under the Pubs Code etc. Regulations 2016. This includes conducting rent reviews, lease or tenancy renewals, lease assignments, dealing with any market rent only (MRO) enquiries, negotiations and appeals and ultimately ending our relationship with you when you leave the pub.

We will also use that data to communicate to you things like price increases, to manage your account with us, to deal with licensing issues, the supply of gaming machines and, if appropriate, food.

When we conduct surveys with you to obtain your feedback about us

From time to time we conduct surveys with you to obtain your feedback about us. These surveys will usually be conducted by third party external suppliers. The feedback is used to measure our performance and is used to help us recognise areas where we are exceeding expectations and to provide feedback on areas that may need improvement.

When we deal with the licensing requirements of your pub

If you are to be the designated premises supervisor (or designated premises manager in Scotland) of your pub we ask you to consent to that appointment by completing and signing a consent form and application form containing your name, address, date of birth, place of birth, nationality, your personal licence number and issuing authority so that we can liaise with the relevant local authority on your behalf.

When you make a payment, sign a direct debit mandate, use our online ordering system or request a refund

In order for you to pay your rent or for any goods or services that Greene King provide, or use our online ordering system, we will need your name, your bank details and may ask you to sign a direct debit mandate form. If you pay for anything with a payment card, we will ask for your name and the card number, start and expiry date, verification code (CVC). We will also need these details to make any refunds.

When you submit queries or complaints

We may ask for your name and telephone number or email address so that we can identify you and discuss your enquiry with you. We will also ask for any other relevant information, such the nature of your enquiry or complaint. We will use this information to take your enquiry and respond appropriately to it, where appropriate in accordance with the Pubs Code etc. Regulations 2016.

When there is an insurance claim

If you need to make a claim under our insurance policies, we will need to ask you for your contact information and for details of the incident giving rise to the insurance claim, to pass to our brokers and insurers. If a member of the public want to makes a claim on our policy in relation to your pub, we will need both their and your information and details of the claim.

When we ask for other people's personal data

If you need to provide us with information about other people, either as part of the application process or at any other time during the course of your tenancy or lease with us, please ask them to read this notice before you do so.

How long do we keep your personal data for?

 

Information about	Is kept until
When you use our websites	Please refer to our cookie policy for information about the lifespan of cookies.
When you make an initial enquiry about our pubs and we send you direct marketing	If you sign up for pub alerts, research information or planning information we will use your data for six months. If you have not engaged with us during this time your data will be removed from our database. When you contact us using Live Chat on our website If you use Live Chat, we will retain the transcripts (including your name and email address) for six months. If you opt out of direct marketing We will keep your name, email address and postal address indefinitely, so that we can ensure we don't accidentally send you direct marketing messages again without you having first opted back in.
When you go through the application process to become one of our partners	If you go through the application process, we will keep your data for 12 months from the date of the application if for whatever reason you don't end up entering into an agreement with us. When we ask you to consent to us verifying your creditworthiness, we will keep the consent form and the related credit check report only during the recruitment and vetting process.
When you undertake training either before or once you become one of our partners	We keep your training records for 6½ years following the end of your tenancy or lease.
When we help you run your business, market services to you, manage our relationship with you and deal with the licensing arrangements for the pub	We will keep most documents and records that are produced during the course of your tenancy or lease for 6½ years following the end of your tenancy or lease. Some documents, notably those that are executed as deeds and other documents that are related to them, will be retained for 12½ years following the end of your tenancy or lease. Licensing application forms, consent forms and premises licences are also kept for this period.
When you join one of our special interest groups such as the Sports Club	We will keep a record of your membership of the relevant club for as long the duration of your tenancy or lease agreement or earlier if you advise us you no longer wish to participate in the relevant club.
When you make a payment, sign a direct debit mandate, use our online ordering system or request a refund	6½ years from the date of the transaction, although direct debit mandates are not retained for more than 12 months after the end of your tenancy or lease. If you pay by card, then payment card details are not retained.
When you submit queries or complaints	6½ years following the end of your tenancy or lease.
When there is a potential or actual insurance claim	6 years if the claim relates to the accident, or 3½ years from the age at which a child becomes an adult, or 3½ years from the date of settlement of a claim, whichever occurs last.
When you make a request to exercise your data protection rights	Information about your request and our response will be kept for 12 months from the date of our final response to you.
When information is relevant to a legal action, proceeding or claim	6 years from the date that the action, proceeding or claim is settled.

Who do we share your personal data with?

Other Greene King companies

Any of the information we collect from you may be shared with other companies within the Greene King group:

Company	Role	Registered Office
Greene King Limited	This is the holding company in the Greene King group	Westgate Brewery, Bury St Edmunds, Suffolk IP33 1QT
Greene King Retailing Limited	These are operating companies that own pubs within the group
Spirit Pub Company (Leased) Limited
Greene King Services Limited	This company employs Greene King Pub Partners' employees
CK Asset Holdings Limited	This is the holding company of the CK Group of which Greene King forms part	7th Floor Cheung Kong Center 2 Queen's Road Central Hong Kong

Each of these companies is bound by the terms of this privacy notice and they are also required to comply with our data protection policies. They are not permitted to use your personal data for their own purposes.

 

Organisations who help us to provide our products and services

We work with a number of third-party suppliers and service providers. Many of these organisations process personal data in order to provide products or services to us or on our behalf. See the third-party data sharing list for more details.

These organisations are bound by the terms of this privacy notice and they are also required to comply with our data protection policies. They are not permitted to use your personal data for their own purposes.

International data transfers

Some of our third-party processors operate outside of the UK. Under these circumstances, before your personal data is transferred outside the UK, we implement at least one of the following safeguards:

• Carry out Risk Assessments to ensure there is a suitable level of protection for your personal data
• Put appropriate controls in place to ensure your personal data has a suitable level of protection where the recipient country is not deemed as adequate, for example standard contractual clauses or encryption

If we are unable to apply any of the above safeguards, we will try to contact you to ask for your consent before we transfer your personal data.

Other situations that may require us to share your personal data

During the application process we will share your data with a credit reference agency to enable us to verify your creditworthiness. Once you become one of our partners, we will share your personal data if we need to do so to protect our business interests, such as to enforce the terms of a contract, pursue an overdue debt, defend our legal rights or to ensure that third parties understand where responsibilities lie as between you and us.

We will share your personal data if we are required to do so by law or by a regulatory authority including the Pubs Code Adjudicator. For example, we may have to share your personal data for the detection or prevention of crime, fraud or money laundering, or to allow a regulator or ombudsman to investigate a complaint you have submitted to them or to provide your data to an independent assessor under the Pubs Code etc. Regulations 2016.

As we develop our business, we might sell or buy group companies or other businesses. This might involve transferring information about our partners to the person buying the businesses. If this happens, the new owner will be bound by the terms of this privacy notice.

Occasionally, we may need to share your data to protect the rights of other organisations or people. In these cases, we will try to contact you to seek your consent first, but this may not be possible, especially in the event of a medical or other emergency.

How do we comply with data protection law?

We have adopted the measures that we believe are necessary to comply with Data Protection law.

Protecting your data

We protect the personal data we hold from theft, accidental loss, corruption and other threats that would have a negative impact on our customers. These protective measures include:

• Not collecting personal data that we don't really need
• Destroying or anonymising personal data securely when we don't need it any more
• Only allowing our staff and our suppliers to process the personal data they need to carry out their duties
• Encrypting personal data to render it useless to anyone who is not authorised to access it
• Making sure that staff are trained on how to handle personal data safely and securely and are fully aware of their personal responsibilities
• Binding our suppliers and partners to the same standards and duties of care that we hold ourselves to
• Protecting our websites, networks and IT systems from unauthorised access and from threats such as denial of service attacks, viruses and malware
• Making periodic checks that all of these measures are working well and making improvements to them when we think we can do better

Being accountable for what we do

As well as the security measures mentioned above, we have a team of people whose job it is to make sure that Greene King does the right thing the right way whenever we're processing personal data. This team includes a Data Protection Officer, who can be contacted using these contact details.

There are a set of checks we apply to make sure we process personal data fairly and transparently. These include:

• Providing you with clear and accurate information about why we need your personal data, what we do with it and how long we keep it for
• Checking that our business interests don't unfairly or unreasonably impact upon you or your rights
• Identifying personal data processing risks and reducing them to an acceptable level
• Responding honestly, clearly and promptly to enquiries we receive from you or from the Information Commissioner's Office

Making sure our processing respects the law

The ICO have published a helpful guide to lawful basis for the general public which you can find here. The lawful basis we rely on for the processing we do are shown in bold typeface in this table:

 

Purpose	Lawful basis
When you use our websites	We process this personal data because it is in our legitimate interests to provide a fully-functioning, accessible and useful website to our customers.
When you make an initial enquiry about our pubs and we send you direct marketing	We process your personal data in these circumstances as we believe it is in our legitimate interests to advertise our pubs and services. If you no longer want to receive our marketing, you have the right to opt out at any time. The easiest way to do this is to follow the instructions in the last marketing message you received.
When you communicate with us through Live Chat on our website	We process your personal data because it is in our legitimate interest to answer your questions about our vacant Pubs, our recruitment process, our agreements and any other pub related question you may have.
When you go through the application process to become one of our licensees	This processing will be part of the pre-contract steps necessary for us to agree the terms of a contract with you. We also believe it is in our legitimate interests for us to undertake credit reference checks about you.
When you undertake training either before or once you become a Greene King licensee	We believe it is in everyone’s interest that you undertake some training before or once you become a Greene King licensee. This will help both your and our businesses to continue to prosper, so this processing is a legitimate interest for us. Some training will be mandatory under the Pubs Code etc. Regulations 2016 or the Licensing Acts in England and Scotland and so this processing is for compliance with our legal obligations.
When we help you run your business, market services to you, manage our relationship with you and deal with the licensing arrangements for the pub	We process personal data for core business activities in connection with the contracts that exist between us. Sometimes we will process this data because it is in our legitimate interests to make you aware of products and services that we offer or can source for you.
When you make a payment, sign a direct debit mandate, use our online ordering system or request a refund	We process personal data for these core business activities in connection with the contracts that exist between us.
When you submit queries or complaints	We receive and respond to lots of different types of enquiry. Generally, our processing will be necessary for us to meet the terms of the contract we have with you. Otherwise we do so because it is in our legitimate interests to allow you to tell us what you think of our service, what we do well and what you think we can improve on.
When there is an insurance claim	If the claim relates to an accident, we record the details primarily for compliance with our legal obligations. The claim may also be processed under the terms of a contract with you or to protect our business interests and so this processing is a legitimate interest for us.
When surveys are completed	We process personal data in these circumstances as we believe it is in our legitimate interests to obtain feedback on the service that we provide you The feedback is used to measure our performance and is used to help us recognise areas where we are exceeding expectations and to provide feedback on areas that may need improvement.
When we evaluate and report on product performance	We process personal data in these circumstances as we believe it is in our legitimate interests to analyse product performance to support you and get the best out of the stocked products. The report is used to help us recognise how products are performing and offer direct support.

Your rights

Data protection laws give you certain rights and as a responsible data controller, we are committed to uphold these for you:

Name of right	Description	How to make a request
Information	You have the right to know what we want your personal data for, what we will do with it, who we share it with and how long we keep it for. This is the primary reason for publishing this notice.	Send any questions you have about our privacy notices to dataprotection@greeneking.co.uk
Access	You have the right to be sent information about the personal data we have about you and a description of what we are using it for. This is also known as a ‘subject access request’, ‘SAR’ or ‘DSAR’.	Send your request to dataprotection@greeneking.co.uk
Rectification	You have the right to ask us not to process inaccurate personal data or to ask us to correct it.	Send your request to dataprotection@greeneking.co.uk Some conditions and limits apply to these rights: you can find out more about these on the ICO website.
Erasure (‘right to be forgotten’)	You have a right in certain situations to ask us to delete your personal data.
Restrict processing	You have a right in certain situations to ask us not to process your personal data.
Object to processing	You have the right in certain circumstances to object to the fact that we are processing some of your personal data.
Portability	You have the right in certain circumstances to ask us to pass some of your personal data to another data controller on your behalf.
Complain	You have a right to lodge a complaint with the UK Information Commissioner’s Office or in some situations, another European Union data protection authority.	Send your complaint to the ICO. You can find a list of all European Union data protection authorities here.
Withdraw consent	Most of the personal data processing we do does not rely on your consent to make it lawful but any consent that we are relying on can be withdrawn by you if you decide you wish to do so.	Follow the unsubscribe instructions in any of the marketing messages we have sent you or send your request to ppadministration@greeneking.co.uk

Detailed information about all of these rights can be found on the ICO website.

Responding to your questions

When you notify us that you want to exercise any of your rights, we will acknowledge your request as soon as possible and ask for any information we may need to verify your identify: if we don't already know who you are, we will ask you to send us a copy of your passport or photo-card driving licence, so that we can check your name, address and signature.

Once we have confirmed your identity, we will validate your request then gather the information we need to be able to respond fully to it.

Whilst we always try to carry out this work as quickly as possible, it may take us up to 30 days to respond to you in full. If your request is particularly difficult to respond to, we may ask you for any further information that will help us respond more quickly or ask you if there is some information that you want particularly urgently. We may also respond to your request in phases, as relevant information becomes available.

If we cannot satisfy your request within 30 days, we will write to you to tell you why, and when we expect to be able to provide you with a full response. If for any reason we decide that we should not respond in the way you have asked us to, we will provide you with our decision and our reasons for reaching it within 30 days.

Changes to this privacy notice

This notice is effective from 5^th March 2024. You can check if the privacy policy has changed by revisiting this webpage at any time. If we make any significant changes to this policy, if we have your email address, we will email you to let you know.

 

 

 

 

 

 

 

 

 

Suggested alternative third party sharing table:

Organisations who help us to provide our products and services

We work with a number of third-party suppliers and service providers. Many of these organisations process personal data in order to provide products or services to us or on our behalf. See the third-party data sharing list below for more details.

Type of Organisation	Type of data shared	Reason for sharing
Credit reference agencies	Contact details, CCJs, Directorships, credit score	To enable us to assess the creditworthiness of applicants for loans or trade credit
Land Registry and Register of Scotland	Contact details, evidence of title to land and property	To enable us to establish authority to trade from an outlet, provide support for a personal guarantee & to assess the assets of individuals as part of the creditworthiness check
Law firms	Contact details, GK account number, details of debt outstanding & any other relevant data held within retention schedule to support debt recovery or completion of loan agreements	To enable us to recover debt and to provide legal services in relation to secured lending
Insolvency service providers	Contact details, GK account number, details of debt outstanding & any other relevant data held within retention schedule to support debt recovery	To enable us to recover debt through the insolvency services provided by supplier
Website and CRM system hosts	Contact details, GK account number, order information	To enable us to respond to online queries or online ordering
Providers of corporate hospitality	Contact details, date of birth, passport details,dietary requirements, medical info	Provision of customer hospitality
Fulfilment providers	Contact details, order information	To fulfil any goods purchased through Greene King
Fulfilment partners	Contact details, GK account number,	To fulfil any goods or services required for site.

If you would like to request further details about who we share data with, please contact us at ppadministration@greeneking.co.uk