How do we comply with data protection law?
We have adopted the measures that we believe are necessary to comply with the Data Protection Act 1998 and we are preparing for the act’s replacement, which will fully embed the General Data Protection Regulation into UK law.
We have also adopted the measures that we believe are necessary to comply with the Privacy and Electronic Communications Regulations 2003. This law sets out an additional set of rules that we must follow whenever we communicate with you via any of our websites and apps, or by telephone, fax, email or text message.
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:
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 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.
Sometime 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 to protect our business interests and so this processing is a legitimate interest for us.
Data protection laws give you certain rights and as a responsible data controller, we are committed to uphold these for you:
Name of right
How to make a request
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 firstname.lastname@example.org
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 email@example.com
You have the right to ask us not to process inaccurate personal data or to ask us to correct it.
Send your request to our firstname.lastname@example.org
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.
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.
You have the right in certain circumstances to ask us to pass some of your personal data to another data controller on your behalf.
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.
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 email@example.com
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 together 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.